July 5, 2011Centers for Medicare and Medicaid ServicesDepartment of Health and Human ServicesAttention: CMS-2328-PBaltimore, MD 21244-1850
CMS-2328-PAOTA comments on proposed rule on the Medicaid Program: Methods for AssuringAccess to Covered Medicaid Services, Federal Register, May 6, 2011.
Dear Sir or Madam:The American Occupational Therapy Association (AOTA), the national professional associationrepresenting the interests of more than 140,000 occupational therapy practitioners appreciates theopportunity to comment on this proposed rule which has the potential to have a major impact onaccess to appropriate services – and appropriate providers of these services -- for children andadults who are Medicaid beneficiaries.Because occupational therapists and occupational therapy assistants provide services to peopleacross the lifespan with a focus on wellness, prevention, rehabilitation, and maintenance of existing function, AOTA is particularly interested in any changes that will have a direct impacton the ability of children, adults, seniors and individuals with disabilities and chronic conditionsto receive the supports and services they need to function as independently as possible.Occupational therapy places a major focus on providing individualized supports and services inthe least restrictive environment. Occupational therapy practitioners have a holistic perspective,in which the focus is on adapting the environment to fit the person, and the person always is anintegral part of the therapy team.Occupational therapy services typically include an individualized evaluation, during which theindividual/family and occupational therapist work together to determine the person’s goals. OTsand OTAs provide customized interventions to improve the person’s ability to perform dailyactivities and reach specific goals. All efforts include an outcomes evaluation to ensure that theappropriate goals have been established and are being met and – if needed -- to make changes tothe intervention plan. Occupational therapy services may include: comprehensive evaluations of the individual’s home and other environments (e.g., workplace, school); recommendations for adaptive equipment and training in its use; as well as guidance and education for familymembers and caregivers.AOTA provides the following specific comments both to (1) offer its support for the innovativekey concepts embedded in this proposed rule; and (2) to offer specific recommendations whichAOTA believes will assist the Department to strengthen the eventual final rule.