As for all E/M visits conducted on the same date as a procedure, there needs to be a separate, significant service performed.
In addition, there is a limitation on the frequency. From the CMS NCD:
According to this National Coverage Determination,
Effective for services furnished on or after July 1, 2002, Medicare covers, as a physician service, an evaluation (examination and treatment) of the feet no more often than every six months for individuals with a documented diagnosis of diabetic sensory neuropathy and LOPS, as long as the beneficiary has not seen a foot care specialist for some other reason in the interim. LOPS shall be diagnosed through sensory testing with the 5.07 monofilament using established guidelines, such as those developed by the National Institute of Diabetes and Digestive and Kidney Diseases guidelines. Five sites should be tested on the plantar surface of each foot, according to the National Institute of Diabetes and Digestive and Kidney Diseases guidelines. The areas must be tested randomly since the loss of protective sensation may be patchy in distribution, and the patient may get clues if the test is done rhythmically. Heavily callused areas should be avoided. As suggested by the American Podiatric Medicine Association, an absence of sensation at two or more sites out of 5 tested on either foot when tested with the 5.07 Semmes-Weinstein monofilament must be present and documented to diagnose peripheral neuropathy with loss of protective sensation.
The examination includes:
A patient history, and
A physical examination that must consist of at least the following elements:
Visual inspection of forefoot and hindfoot (including toe web spaces);
Evaluation of protective sensation;
Evaluation of foot structure and biomechanics;
Evaluation of vascular status and skin integrity;
Evaluation of the need for special footwear; and
Patient education.