On November 28, 2017, AOPA participated in a Special Open Door Forum hosted by the Centers for Medicare and Medicaid Services (CMS). The purpose of the Special Open Door Forum was to receive input from experts and stakeholders regarding proposed changes to the DMEPOS quality standards that would expand the definition of the term “molded to patient model” to include diabetic inserts that are custom fabricated from digital or virtual models using a direct milling process.
During the Special Open Door Forum AOPA expressed its concern regarding a frequently asked questions document published by CMS prior to the forum. In this document, CMS indicated that inserts that were fabricated using a direct milling process would be reimbursed approximately 14% lower than those that were molded over a physical model of the patient’s foot. AOPA and other industry representatives questioned this apparent “toll” on providers who chose to provide direct milled inserts that are identical to inserts fabricated using the older technology of molding the insert over a model of the patient’s foot. AOPA was not satisfied with the answer that was provided by CMS officials during the Special Open Door Forum and followed up with a letter to CMS reiterating the question and challenging the response provided by CMS officials.
AOPA will incorporate its concerns that were addressed during the Special Open Door Forum into its full comments on the proposed changes to the DMEPOS quality standards. AOPA’s comments will be submitted to CMS by the December 11, 2017 deadline.