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Facilities have only a limited time in which to respond to a final rule from the Centers for Medicare & Medicaid Services (CMS) that seeks exemption from the durable medical equipment (DME) supplier accreditation for physical and occupational therapists who fabricate custom upper extremity orthoses.

The deadline for comment to CMS-6012-P, “Establishment of Special Payment Provisions and Requirements for Qualified Practitioners and Qualified Suppliers of Prosthetics and Custom Fabricated Orthotics,” is March 13.

The proposed rule, while serving to eliminate the exemption from DME supplier accreditation for those who fabricate custom upper extremity orthoses would in turn require licensed physical and occupational therapists to seek additional training and certification by the American Board for Certification in Orthotics and Prosthetics, Inc. (ABC), or by the Board for Orthotist/Prosthetist Certification International (BOC). 

Occupational and physical therapists who work in upper extremity rehabilitation are certified as hand therapists (CHTs) by the American Society of Hand Therapists after completing certification requirements and testing through the Hand Therapy Certification Commission (HTCC).

According to the American Physical Therapy Association (APTA), this proposed rule “aims to tighten up requirements around who CMS will work with when it comes to making and furnishing devices ranging from glass eyes to exoskeletal systems and finger orthotics.” According to the APTA, “the most notable parts of the proposed rule have to do with how a provider would become qualified to participate in the system.” According to a fact sheet from CMS, while PTs are among the providers who could participate, they would need to be “licensed by the state (as a qualified provider of prosthetics and custom orthotics) or … certified by the American Board for Certification in Orthotics and Prosthetics … or by the Board for Orthotist/Prosthetist Certification.”

According to the HTCC, specialty certification in hand therapy recognizes “occupational therapists and physical therapists with advanced clinical knowledge, experience, and skills in the practice of hand and upper extremity rehabilitation. It assists consumers and the healthcare community in identifying those therapists who meet the rigorous standards required of CHTs, including three years of practice experience with 4,000 hours or more in direct practice in hand therapy and successful completion of a comprehensive test of advanced clinical skills and theory in upper quarter rehabilitation.”  The HTCC indicates that there are 6,228 CHTs worldwide.

CMS is accepting comments on the proposed rule through March 13, 2017. Information is available from the following therapy advocacy organizations to assist in developing a response to the CMS proposed rule:

Comments may be submitted in writing or electronically (with ease) at:  https://www.regulations.gov/document?D=CMS-2017-0004-0001 

If your facility provides upper extremity rehabilitation and fabricates custom orthoses integral to the rehabilitation process, action is required in the next few days.


Nancy J. Beckley, MB, MBA, CHC

Nancy Beckley is founder and president of Nancy Beckley & Associates LLC, providing compliance planning and outsourced compliance services to rehab providers in hospitals, rehab agencies, and private practices. Nancy is certified in healthcare compliance by the Healthcare Compliance Certification Board. She is on the board of the National Association of Rehabilitation Providers and Agencies. She previously served on the CMS Professional Expert Technical Panel for Comprehensive Outpatient Rehabilitation Facilities. Nancy is a familiar voice on Monitor Mondays, where she serves as a senior national correspondent.

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