In Feb. 2012, CMS identified specific Healthcare Common Procedure Coding System codes that were considered off-the-shelf (OTS) orthoses and requested public comments on the preliminary list. After reviewing approximately 185 comments, CMS released a summary of responses, as well as a list that identifies the 2014 Healthcare Common Procedure Coding System codes for OTS orthoses.

According to the list, 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, including leg, arm, back and neck braces.

Section 1847(a)(2) of the Social Security Act includes OTS orthoses as one of the categories of items subject to competitive bidding. However, CMS has not determined the schedule for bidding OTS orthoses, 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.

A list of the 2014 OTS orthotic codes and responses to OTS comments can be viewed here.