CMS-R-131 Comment # 9

American Orthotic &

RostheticAssoci

June 14,2007

Centers for Medicare and Medicaid Services
Officer of Strategic Operations and Regulatory Affairs
Division of Regulations Development - C
Attention: Bonnie L. Harkless
Room C4-26-06
7500 Security Blvd.
Baltimore, MD 21244-1850
Dear Ms. Harkless:
The American Orthotic and Prosthetic Association (AOPA), the leading business
trade group in the orthotics and prosthetics industry with a full-range of services
that support patient care facilities and the companies that manufacture and
distribute O&P products, would like to submit a comment to CMS-R-131, revision
to Advanced Beneficiary Notice of Noncoverage (ABN).
AOPA understands the inclusion of the word "noncoverage" eliminates the need
for suppliers to provide a separate notice of exclusion from Medicare benefits.
However, we feel this may be confusing to the supplier conimunity about when to
use this document since its main purpose is used to define items that are
deemed medically unnecessary. Suppliers are not required to specifically notify
beneficiaries when an item or service is a statutorily noncovered benefit. The
inclusion cf the word noncovered in the revised P.BN may lead to undue
confusion regarding the proper use of the ABN.
If you need further information about our comments, please contact Joe
McTernan, Director of Reimbursement Services, by phone (571) 431-081 1, or by
email [email protected].

Kathy ~ o d s o n
Senior Director, Government Affairs