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Guidance Materials on Osseointegrated Advocacy Available

Thursday, August 7, 2014  
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Guidance for Submitting Comments

Guidance for ACI Alliance Members:

Advocacy on Osseointegrated Devices

The attached materials have been developed to help you submit comments regarding the proposal by the Centers for Medicare and Medicaid Services (CMS) to change the classification of Auditory Osseointegrated Devices under Medicare. Instead of covering these devices (brand names Baha, Ponto), CMS is suggesting that Medicare will now view the bone anchored prosthetic device as a hearing aid and exclude it as a covered benefit. This would affect both new surgeries and aftercare services for existing Medicare patients.  Likely such a change, if implemented by CMS, would also affect coverage by many private insurers which are currently covering the bone anchored device. The proposal specifically exempts cochlear implants and ABI devices.

ACI Alliance Board Members and staff have already held multiple meetings with CMS officials. We have also met with Members of Congress. We urge you to send in your own comments expressing your concern to help generate strong national opposition to this change, which would dramatically impact on access to care for these devices.  There is a real likelihood that without significant input from the hearing loss community that this proposal will be implemented.

Following this introduction, please find two items intended to help you write your own letter as a clinician, educator, parent or consumer: (1) Key Messages/Facts and (2) Guidance for Letters. Even if you primarily work with children, please emphasize the importance of this intervention for older adults under Medicare. Please write a letter in your own words and do not use the same language that is in the attached Key Messages document.

Comments are due to CMS on September 2. The best way to submit is electronically via the CMS website.  This link takes you directly to the correct place to submit:!documentDetail;D=CMS-2014-0092-0002. It is a good idea to note that this is CMS-1614-P.  Include this reference in the template for your letter.

If you wish to read the Federal Register in which this proposal is contained, go to: The osseointegrated device proposal begins on page 89 (40295 of the July 11 Federal Register).  Do not be confused by the reference to "End-Stage Renal Disease;" the discussion of Osseointegrated Devices comes toward the end of the proposed rule.

When submitting, you can either paste your comments directly on the submission site (maximum of 5,000 characters) or you can attach a letter to website.  Keep in mind that if you paste comments in, there is a 5,000 character limit (which is less than two pages). 

Please send a copy of your letter submission so that we can know the impact of our outreach effort to our executive director, Donna Sorkin  Thank you so much for your interest in ensuring access to appropriate hearing care.

There are additional materials in support of our efforts at the following pages:

  1. Background Messages
  2. Suggested Letter Format
  3. Osseointegrated Bibliography

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