Podiatry Coding & Billing Alert

Hint: Medicare’s routine foot care policy has a systemic condition exception.

Reporting routine foot care can be quite a challenge because of the specific rules, exceptions, and list of systemic diseases you must know to submit clean claims.

Bust the following routine foot care myths to help your practice put its best foot forward regarding this policy.

Myth 1: Medicare Generally Reimburses for Routine Foot Care Services

Truth: As a general rule, routine foot care is excluded from Medicare coverage, said Carynne Godfrey, Noridian Part B Medicare provider outreach and education representative, in a recent webinar.

Medicare considers the following foot care services routine:

• The cutting or removal of corns and calluses
• The trimming, cutting, clipping, or debriding of nails
• Other hygienic and preventive maintenance care, such as:

                 ◦ Cleaning and soaking the feet
                 ◦ Using skin creams to maintain skin tone of either ambulatory or bedfast patients
                 ◦ Any other service performed in the absence of localized illness, injury, or symptoms involving the foot.

Myth 2: Medicare Offers No Exceptions to Routine Foot Care Policy

Truth: An exception to Medicare’s routine foot care policy occurs when a patient has a systemic condition like a metabolic, neurologic, or peripheral vascular disease.

“Foot care that would be otherwise considered routine may be covered when that systemic condition results in severe circulatory embarrassment or areas of that diminished sensation in your patient’s legs or feet,” according to Godfrey.

Don’t forget: The systemic condition must be of sufficient severity that it may pose a hazard if a non-professional performs the service, Godfrey added.

Systemic conditions that might justify coverage for routine foot care include but are not limited to diabetes mellitus*, Buerger’s disease (thromboangiitis obliterans)  alcoholism, and associated with carcinoma*.

Other exceptions: Another exception to the routine foot care rule can occur in certain circumstance when services that are ordinarily considered routine may be covered if they are performed as a necessary and integral part of other covered services like th diagnosis and treatment of ulcers, wounds, and even infections, according to Godfrey.

In addition, the treatment of warts, including plantar warts on the foot is covered to the same extent as services provided for the treatment of warts located elsewhere on the body, Godfrey adds.

Myth 3: At-Risk Policy Not Relevant to Routine Foot Care

Truth: You should absolutely be aware of CMS’s at-risk policy regarding routine foot care. According to this requirement, the patient must be exposed to significant risk if the routine foot care is rendered by anyone other than the DPM, MD, DO, or non-physician practitioner (NPP), according to Godfrey.

“We, as the contractor, may make a presumption of coverage where the claim or other available evidence discloses certain physical or clinical findings that are consistent with an at-risk status, such as a diagnosis and treatment of the diabetic ulcer, wounds and infections,” Godfrey said. “So, this at-risk requirement relates directly to problems associated with infections, prolonged bleeding, and impaired wound healing, leading to complications with a potential loss of a limb.”

Godfrey added that medical conditions not associated with these complications, like blindness, upper body muscle weakness, arthritis of the hands or back, don’t demonstrate a qualified at-risk status.

Myth 4: You Don’t Need to Pay Attention to Asterisks

Truth: Medicare uses asterisks to indicate the conditions where routine foot care will be covered only if the patient is under the active care of a physician who documents the patient’s condition. For example, you can see that two of the conditions listed under Myth 2, include an asterisk: diabetes mellitus* and associated with carcinoma*.  

Active care defined: “Active care of a physician is met if the claim or other available evidence such as your beneficiary’s history, discloses that the patient has seen an MD or DO for treatment and/or evaluation of that asterisked disease during the six-month period, prior to rendering those foot care services,” according to Godfrey.

Myth 5: There is No Time Limit for Routine Foot Care

Truth: If the conditions of coverage are met, routine foot care services will typically be covered once every 60 days.

Myth 6: You Can Bill Routine Foot Care as E/M Service

Truth: You cannot bill routine foot care as an evaluation and management (E/M) service because they are two separate services, according to Godfrey.

Don’t forget: All services must be documented, and the documentation must support the level of service being billed, Godfrey emphasized.