Disappearing footwear guidelines conjure concern

Wednesday, June 30, 2004

BALTIMORE - New National Supplier Clearinghouse guidelines dictating who can supply therapeutic footwear arose amid a cloud of questions and then abruptly disappeared, leaving nothing but lingering questions.

On May 14, the NSC posted new guidelines for diabetic footwear suppliers that limited who was qualified to furnish the product. While the current rule defines suppliers as a podiatrist or other qualified individual - which has long been interpreted to include pharmacists and HMEs - the bulletin limited suppliers to podiatrists, pedorthists, orthotists, prosthetists or certified orthotic fitters.

The new guideline was soon removed without comment on May 25, but not without inducing confusion and concern. Suppliers speculate that the move foreshadows anticipated action for CMS on the issue of therapeutic footwear. The administration has been in the process of reexamining those supplier qualifications for more than a year.

“I don’t doubt in the future that CMS could take this same position [as the NSC],” said Kelly Pickens, an attorney at the Health Law Center, “but they need to do so through the appropriate channels.”

“The NSC was looking to put some kind of credentialing component on there,” said Bill Popomaronis, The National Community Pharmacists Association’s (NCPA) director of pharmacy specialty services. “Pharmacists were in a quandary as to what to do and how to proceed,” said Popomaronis.

The NCPA wants to protect the ability of 5,000 of its members to provide therapeutic footwear. It believes a pharmacist’s extensive education and knowledge of diabetes, its effects and treatment qualifies him to provide the footwear. In addition, The NCPA last year developed a 40-hour program that trains pharmacists how to properly fit the shoes.

“The pharmacists are policing themselves,” said Popomaronis. “What we want is recognition from CMS that that we have a top-of-the-line program and that we achieve the standard of care everyone deserves.”

The NSC announcement sparked concern from the supplier community as well. Pickens she received calls from clients concerned about losing their supplier numbers in light of the change.

“[This posting] made many suppliers of therapeutic footwear in violation of supplier standard number one,” she said.

In December 2002, DMERC Region A similarly attempted to redefine the qualifications for providing therapeutic footwear, but the change was retracted one month later.

“More changes could come in three months or three years. Nobody knows.” said Popomaronis. “For now, we are back to the status quo.”