Practice Guidelines cited as “relevant and credible” by CMS

The Centers for Medicare & Medicaid Services (CMS) cited AOTA’s practice guidelines as "relevant and credible" in a Notice of Benefit and Payment Parameters (NBPP) proposed rule released on December 28, 2021. The NBPP is the annual regulation governing the Marketplaces created by the Affordable Care Act.

In the proposed rule, CMS proposes a new framework for enforcing nondiscrimination in benefit design, to ensure that benefit limitations and coverage requirements are based on clinical evidence. A plan that is free from discriminatory benefit design is one that is “clinically based, that incorporates evidence-based guidelines into coverage and programmatic decisions and relies on current and relevant peer-reviewed medical journal article(s), practice guidelines, recommendations from reputable governing bodies, or similar sources,” according to the proposed rule.

CMS points to practice guidelines from health professional associations as appropriate sources of clinical evidence that should form the basis of nondiscriminatory benefit design, specifically citing AOTA’s evidence-based practice guidelines as an example. They also point to peer-reviewed medical journals – noting that journals of non-M.D. health professionals like occupational therapy should be considered.

AOTA’s Practice Guidelines are developed to assist occupational therapy practitioners in providing evidence-based interventions and serve as a reference for people who manage, reimburse, or set policy regarding occupational therapy services. They are created by content experts and based on the findings from focused systematic reviews of published scientific research. Each Practice Guideline is reviewed by a multidisciplinary advisory group, which includes external stakeholders (e.g., consumers) and policy analysts.

Access the NBPP proposed rule (pp.663-665) for complete details.

Learn about AOTA’s Practice Guidelines and other resources for evidence-based practice.