Chris Mata-FL

We would like to thank you for your insight into offering better care for patients receiving orthotic and prosthetic care. The proposed standards will assist our profession as we continue to work under a medically based model. Of particular interest to my organization is page 15 paragraph 3 which states: Individuals supplying the item set out in this appendix must possess specialized education, training, and experience in fitting these types of prostheses and when appropriate, certification and or licensing. This language should also include the word orthoses along with prostheses so as not to make it vague and include both disciplines. It is our interpretation that the definition of specialized education, training and experience should follow that as described by The American Board of Certification. (The following information was obtained from ABC's website) We believe that CMS should follow the criteria below when finalizing your Quality Standards. Educational Standards are listed below The education requirements for ABC practitioner certification are the only orthotic and prosthetic educational standards recognized by the <http://www.caahep.org/> Commission on Accreditation of Allied Health Education Programs (CAAHEP). These Standards and Guidelines for an Accredited Educational Program for the Orthotist and Prosthetist are the minimum standards of quality used to accredit programs that prepare individuals to enter the profession of orthotics and prosthetics. Accreditation by CAAHEP is in cooperation with the <http://www.ncope.org/> National Commission on Orthotic and Prosthetic Education (NCOPE) which accredits the orthotic and prosthetic clinical residency program. The Standards and Guidelines serve as the basis for education and clinical residency requirements established by ABC for individuals seeking to pursue a career as an Orthotist or Prosthetist. Requirements are listed below: * A baccalaureate degree in orthotics and prosthetics -or- * A baccalaureate degree in any major and an orthotics or prosthetics certificate from a CAAHEP accredited program -and- * A 12-month <http://www.ncope.org/> NCOPE accredited residency program An NCOPE residency program is defined as follows: Post-graduate clinical training is an extension of orthotic and prosthetic education. Residency evaluation and supervision are stressed as part of the <http://www.ncope.org/> NCOPE accredited residency programs. Residents are supervised by ABC certified practitioners throughout the process of patient care, constructive feedback is provided by the supervisor, and clinical responsibilities are graduated by progressive levels of independence to enhance judgment, skills and clinical expertise. The range of residency sites is varied including private practices, multi-site practices, hospital based practices, and university based practices and rehabilitation facilities. To qualify to be a residency site the facility must be an ABC accredited facility. Residency allows the ABC certified practitioner to invest in the professional development of the next generation of practitioners. Board examinations taken after completion of the residency include: ABC's certification programs provide professional recognition to Orthotists and Prosthetists that meet educational and residency requirements and pass the examinations. The practitioner examinations consist of three separate exams which measure different knowledge and skills. The first examination is a multiple choice Written Exam that documents those candidates possesses a critical core of knowledge related to their field. General knowledge assessed on the written exam may include anatomy, kinesiology, material science, and practice management. The written simulation examination constitutes the second part of the examination program and measures candidates' clinical decision-making skills through an interactive format. The simulations imitate lifelike situations an Orthotist or Prosthetist might encounter in daily clinical practice. The third examination, the Clinical Patient Management (CPM) examination assesses candidates' professional role and responsibilities. The CPM requires candidates to demonstrate to an examiner his or her practical abilities in a clinical environment. Skills such as patient evaluation, prescription criteria, measurement techniques, fitting, alignment and appropriate handling of patients are evaluated. The development of valid examinations begins with a clear and concise definition of the knowledge, skills and abilities needed for competent job performance. The questions on the examination were developed by content experts using tasks identified in the ABC Practice Analysis of the Disciplines of Orthotics and Prosthetics. The Practice Analysis outlines contemporary orthotics and prosthetic practice and provides the analytical basis for the written simulation and clinical patient management examinations. The Practice Analysis is available at no cost from ABC and is provided to all examination candidates. Continuing education requirements are listed below: ABC has long recognized the need for effective professional continuing education. Continuing education, which is the norm in the health care profession, is meant to maintain and improve the healthcare system and delivery of services. ABC credentialed individuals must seek education to meet two continual demands: 1) to maintain performance at the basic level of professional competence; and, 2) to advance training and specialized skills beyond the basic level. The content of continuing education program is within the body of knowledge and skills generally recognized and accepted by the profession as encompassing the basic sciences, the discipline of clinical orthotics, prosthetics and pedorthics, and the provision of healthcare to the public. Included are programs that provide leading edge scientific information that is at the forefront of research in the O&P profession. This definition and the rules applied to the continuing education programs are sufficiently broad to permit O&P professionals to undertake continuing education activities relevant to their professional responsibilities. All continuing education opportunities submitted for recognition should comply with this definition. Single Discipline (CP or CO) Practitioners: 1. Seventy-five (75) credits must be earned during the five year cycle. At least two- thirds (50) of the required credits must be Category I scientific credits. 2. One-third(25) may be Category II credits. Although an unlimited number of credits maybe earned during each five year period, no more than 25* Category II credits will be counted toward satisfying the continuing education requirement. 3. A maximum of 25* credits may be Business credits. These may be either Category I or Category II, however they may not be counted toward satisfying the required 50 Category I scientific credits. Dual Discipline (CPO)Practitioners: 1. One hundred (100) credits are required within the five year cycle. A minimum of seventy-five (75) credits must be Category I scientific credits. Although an unlimited number of credits may be earned during each five year period, no more than 25* Category II credits will be counted toward satisfying the continuing education requirement. 2. Of the total number of credits required for MCE, a maximum of 25* credits may be Business credits. These may be either Category I or Category II, however they may not be counted toward satisfying the required 75 scientific credits. It is the belief of myself and our profession that in order to provide services to, CMS patients, it be critical to meet and exceed educational requirements set by our profession. This ensures that a base knowledge and skill set has been obtained by the Orthotic and Prosthetic practitioners. Without these standards CMS will not have a good method of ensuring proper care. Thank you for your time and consideration I hope this will make it into your standards.