Call to Action
We apparently have received the attention of the White House. The White House Disability Liaison said that the White House was impressed that we got over 100,000 so quickly and are not quite sure how to respond. They are investigating the issue. She said, “I think this is the first disability related petition that has made it over 100,000 signatures, so we could be making history here.”
Truly awesome and thanks to each of you for your efforts! Now let’s keep the pressure mounting by sending this template letter (or one of your own) to the folks below (or anyone you think may be helpful). Be sure to forward to all your contacts!
1. Open up to send a blank new email.
2. Copy and paste this next set of email addresses into the 'TO:' line:
Sean.Cavanaugh@cms.hhs.gov, firstname.lastname@example.org, email@example.com, Larry.Young@cms.hhs.gov,firstname.lastname@example.org
3. Add your name, age, City and State at the bottom of the letter where noted.
4. Press SEND to get the word out! THANK YOU for your help.
I write to offer my comments on the Draft/Proposed Local Coverage Determination for Lower Limb Prostheses (DL337878) published on July 16, 2015.
I strongly oppose many aspects of this proposed LCD and ask that you rescind this proposal today. I encourage you to meet with organizations that represent patients, prosthetists, physicians and other providers to develop more reasonable coverage policies.
The draft policies will do little more than restrict patient access to the current standard of care and force amputees into prostheses that are less functional and less able to meet their individual needs. Medicare may save some money in the short term, but spend far more on the consequences of not providing modern prostheses to amputees.
The LCD will turn back the clock on amputees by forcing patients into outdated prosthesis that are simply less functional than current prosthetic practice allows. The same thing will occur with commercial payers and others like the VA, which will eventually adopt the changes in the LCD, if it is finalized.
Prosthetic limb care in this country is a success story in the health care area. Veterans with limb loss from recent wars have returned to active lifestyles and some have returned to active duty. Developments in prosthetics have also impacted the general amputee population, raising the standard of care and dramatically improving people’s lives, including my own. The activity levels of today’s amputees are truly amazing and this reduces health care costs over the long term by having a healthier, more active Medicare amputee population.
The Proposed LCD represents a total rewriting of the existing prosthetic coverage policy for lower limb prosthesis. It is not clear why this is necessary given the fact that Medicare has spent less on prosthetic services and devices every year since 2010.
This LCD literally punishes patients by denying them access to the very advances that have produced such good outcomes for amputees in recent years. The Proposed LCD is clearly designed to force patients into cheaper and older prosthetic technology in order to create short term Medicare savings, but at what expense to the patient?
The major problems with the Proposed LCD are as follows:
1. The LCD restricts access to the most functional prostheses by covering only the most basic components in preparatory prosthesis for new amputees and eliminating consideration of functional potential—a long-standing principal of rehabilitation—when assessing the functional level of an amputee
2. The LCD also prohibits access to modern technology to anyone who uses a cane, crutch, or walker to assist him or her, either routinely or only on occasion. It eliminates for certain patients coding and coverage of widely-used and extremely effective prosthetic feet, knees, ankles, vertical shock components, prosthetic liners, fitting techniques, suspension systems, and other components that comprise the current standard of care.
3. The LCD creates new procedures for being prescribed prosthesis that will delay and, in some cases, deny prosthetic care to patients who could otherwise be successfully rehabilitated. New requirements include multiple physician visits, participation in full rehabilitation programs, independent functional assessments, and extensive documentation which must be undertaken before a prosthetist actually begins to fit a patient with a prosthetic limb. Recovering from an amputated limb and learning to walk again on a prosthesis is not easy, especially later in life. There is no doubt this new policy will result in increased numbers of patients giving up, relying on wheelchairs to get around, becoming more sedentary, winding up in nursing homes and worse, dying prematurely.
4. The new LCD marginalizes the expertise of the prosthetist, the health care provider with the most intimate knowledge and understanding of the best prosthetic options and alternatives. The prosthetist is completely omitted from the determination of the functional level, which defines the level of prosthetic technologies available to treat the condition, and the prosthetist’s clinical notes are not even considered part of the medical record when Medicare determines whether the prosthetic care is “medically necessary.”
5. Finally, virtually none of the major changes proposed in the draft LCD are supported by medical or clinical evidence, a requirement of LCD’s according to the Medicare rules and regulations.
For these reasons, I urge you to stop this Proposed LCD process today, rescind the proposal, reconsider these policies by engaging patients, prosthetists, and member of the team of rehabilitation professionals, and start from scratch to design a more reasonable LCD that reflects the need for patients with limb loss to take advantage of the outstanding gains we, as a country, have made in prosthetic limb rehabilitation
Thank you for your consideration of these comments.