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OTS Orthotics

Off-The-Shelf (OTS) Orthotic HCPCS Codes

Section 1847(a)(2) of the Social Security Act (the Act) defines OTS orthotics as those orthotics described in section  1861(s)(9) of the Act for which payment would otherwise be made under section 1834(h) of the Act, which require minimal self-adjustment for appropriate use and do not require expertise in trimming, bending, molding, assembling, or customizing to fit to the individual.  Orthotics that are currently paid under section 1834(h) of the Act and are described in section 1861(s)(9) of the Act are leg, arm, back and neck braces.  The Medicare Benefit Policy Manual (Publication 100-02), Chapter 15, Section 130 provides the longstanding Medicare definition of “braces.”  Braces are defined in this section as “rigid or semi-rigid devices which are used for the purpose of supporting a weak or deformed body member or restricting or eliminating motion in a diseased or injured part of the body.”

CMS regulations at 42 CFR 414.402 also define the term “minimal self-adjustment” to mean an adjustment that the beneficiary, caretaker for the beneficiary, or supplier of the device can perform and that does not require the services of a certified orthotist (that is, an individual who is certified by the American Board for Certification in Orthotics and Prosthetics, Inc., or by the Board for Orthotist/Prosthetist Certification) or an individual who has specialized training.

The download section of this web page contains the final list that identifies the 2014 Healthcare Common Procedure Coding System (HCPCS) codes considered OTS orthotics.  Items classified under these codes require minimal self-adjustment for appropriate use and do not require expertise in trimming, bending, molding, assembling, or customizing to fit the beneficiary.  Subsequent coding updates to the OTS list will be included in program instructions.

Suppliers of any orthotic other than an OTS orthotic must be in compliance with Appendix C of the DMEPOS quality standards, which specifies that suppliers must possess specialized education, training, and experience in fitting and certification and/or licensing.

Please note that in some cases there are two codes in the HCPCS that may both describe a particular prefabricated orthotic product, one code for when the device is furnished OTS, and a second code for when the device is furnished with custom fitting.  In these cases, and in the case of any code for a prefabricated orthotic that requires more than minimal self-adjustment and requires expertise in fitting or customizing, the code that describes a custom fitted orthotic cannot be used unless the custom fitting services have been performed and the supplier is in compliance with Appendix C of the DMEPOS quality standards.

Section 1847(a)(2) of the Act includes OTS orthotics as one of the categories of  items subject to competitive bidding.  CMS has not determined the schedule for bidding OTS orthotics, but will identify the specific OTS orthotic codes included in a competitive bidding program through program instructions or by other means, such as a CMS or contractor website posting.