Greetings!

In collaboration with ASHT and leaders in the field of hand therapy a “template” letter in response to CMS regarding their proposed rule change for orthotics reimbursement has been developed and is attached. We encourage you to submit a letter to CMS in response to this proposed regulation change. Please review the following important points when using the template letter:

• Look through and delete any points which do not pertain to you  - For example: whether you are an OT or a PT.
• Feel free to delete or modify any items which you do not feel accurately represents your personal view.
• Feel free to add any content which further expresses the personal impact this rule would have on you and or your practice.          

Letters are due by March 13, 2017 and may be mailed to the address on the header of the template letter or electronically submitted here.  You may download the response letter template here.

As background, Rule CMS-6012-P ("Establishment of Special Payment Provisions and Requirements for Qualified Practitioners and Qualified Suppliers of Prosthetics and Custom Fabricated Orthotics), published in the Federal Register January 12, 2017, removes exemptions to quality standards and orthotic certification for OTs and PTs, and would require licensure in orthosis fabrication by the state or the American Board for Certification in Orthotics and Prosthetics or the Board for Orthotist/Prosthetist Certification or a program "approved by the HHS Secretary."Suppliers who do not meet the standard will not receive payment for custom-fabricated orthoses, and may face revocation of both their Medicare and DMEPOS eligibility. For more information on the legislation and for updates please monitor the ASHT website's legislative section.