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AOPA: Proposed LCD “Major Leap Forward” for K2 Prostheses Patients
The public comment period is open through March 2.

January 24, 2024 by Laurie Watanabe

The American Orthotic & Prosthetic Association (AOPA) is applauding Medicare’s proposed local coverage determination (LCD) change involving lower limb prostheses.

In a Jan. 18 news announcement, AOPA described the proposed LCD as “a major leap forward in the care of K2 patients.”

The association added, “Under the proposed changes, CMS [Centers for Medicare & Medicaid Services] will now allow limited coverage of microprocessor-controlled knees for select patients who are classified as K2, instead of limiting microprocessor knees to patients classified as K3 and above.”

A change in K level qualification

The Amputee Coalition described K levels as “a rating system used by Medicare to indicate a person’s rehabilitation potential. The system is a rating from 0 through 4, and it indicates a person’s potential to use a prosthetic device if they had a device that worked well for them, and they completed rehabilitation to use the device properly.

“Your K-level designation is important because it is the driving factor in the decision on what prosthetic device to provide to you and the payment for that prosthetic device. Simply stated, payment by Medicare (and many insurers as well) is guided by the person’s K-level designation.”

Whereas Medicare has required a K3 designation to qualify for a microprocessor-controlled prosthetic knee, the new LCD “proposes modifications to the coverage criteria for microprocessor-controlled prosthetic knees (MPKs) for Medicare Functional Classification Level (MFCL) 2 beneficiaries with lower-limb amputations who require a prosthetic knee based on the best available evidence.

“Additionally, the proposed LCD proposes that the coverage criteria for prosthetic feet be modified to allow coverage of a compatible foot when coverage criteria for an MPK are met. KX, GA, GY, and GZ modifier requirements have also been posed for inclusion, for all codes, to facilitate claims processing and assist in the prevention of improper claims payments.”

Comment period open through March 2

CMS and the DME MACs are taking public comments on the proposed LCD through March 2, and they will also hold a public meeting on Feb. 22.

“AOPA is currently reviewing the LCD changes and will provide appropriate feedback and comments,” the association said.

Stakeholders can register now to attend the virtual meeting. Attendees who want to present oral comments during the meeting must register by Thurs., Feb. 1, at 5 p.m. Eastern, and must submit their materials (e.g., slides) by Feb. 8.

Participants can also dial into the meeting by calling (866) 901-6455 and using access code 956-268-529.

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