Don’t Stumble over Routine Foot Care

Routine foot care is probably the most difficult thing for a Podiatry practice to manage. It takes a village to make sure all the proper steps are taken in order to get paid. This is because Medicare has a coverage policy that states the routine trimming of nails and removal of calluses or corns is statutorily excluded. What does that mean?

Basically, it means that the service excluded is not a covered Medicare Benefit. Did you know that you are not required to obtain an ABN signature for statutorily excluded services? Many times we collect a signed ABN form from patients when we expect that a covered service may not be paid, but when it’s a non-covered service you are within your rights to collect from the patient for Statutorily excluded services. You will want to be very transparent with patients and give them a breakdown of the charges, especially now that it will be required as part of the No Surprise Billing act for patient responsible charges.

Routine Footcare Coverage

For the instances when you can bill Routine foot care to Medicare for a medically necessary claim, you can find more information in the LCD (Local Coverage Determination) policy on Routine foot care. ( L35138). You can also find the information on the policy in the IOM or Internet Only Manual CMS IOM Publication 100-02, Medicare Benefit Policy Manual, Chapter 15, Section 290 Foot Care

Are you Interpreting your LCD policy correctly? It can be a lot to take in when we must review so many policies. This policy has many nuances that are worth reviewing so we can interpret the proper way to bill for Routine Footcare and understand the circumstances when it falls into Medical Necessity and can be paid.

In the policy, it gives you covered indications or reasons why routine foot care could be covered. Per the Policy, the conditions listed “represent systemic conditions that may result in the need for routine foot care”. This is important to know because when a patient has one of the conditions such as chronic venous insufficiency or peripheral vascular disease, it can be dangerous for them to have their nails trimmed and it would require it to be performed by a physician.

You will also see a imitations area that specifically points to Article A52996 which will give you further guidance on the appropriate ICD10-CM codes to use and in the proper order. Lastly, you will see the documentation guidelines, which are very important because as we know documentation is key for proper coding and reimbursement. Let’s go back to the medical necessity article A52996. This is where much of the claim error and denial rates stem from, so I will walk you through how to interpret the guidelines. You can go to the bottom of the LCD policy to locate the link to Article A52996 and you will then locate the CPT®️ codes in the article and directly below it all of the ICD10-CM codes that support medical necessity. You will also notice they give you the important modifiers that you need to append based on your provider documentation:

  • Q7 – 1 Class A finding Ex:( non-traumatic amputation of the foot or integral skeletal portion thereof)
  • Q8 – 2 Class B findings Ex: (Absent posterior tibial pulse)
  • Q9 – 1 Class B and 2 Class C findings Ex: (Claudication or Burning in addition to a Class B finding)

You will need to make sure your physician identifies these findings for you in order to justify payment as a medically necessary service. Sounds pretty easy right? Well, there is another LCD policy we must reference for routine foot care.

In my years of podiatry billing, I had to refer to the LCD L35013 for the Debridement of Mycotic Nails. This is a condition that is covered and has coverage limitations, indications, and documentation guidelines you will want to review. Again, you will find the Article near the end of the policy and for this one, it is labeled A56640: Billing and Coding: Debridement of Mycotic Nails. This one is important because it has very specific instructions on the order of ICD10-CM codes to ensure proper payment. If you have a patient with mycotic nails, you will use this policy and according to the policy L35013 instructions, you can refer back to our original Routine foot care policy L35138 if they do not have mycotic nails. It is important that you understand the limitations of frequency and the order of codes. The article specifically refers to CPT codes 11720 and 11721. It informs you that “ICD-10-CM code B35.1 must appear on each claim in addition to one of the other ICD-10-CM codes below that indicates secondary infection, pain, or difficulty in ambulation.”

Master Good Communication

Although there are many guidelines and policies, you can be successful if you have very clear communication with all members of the staff. Medicare requires that in addition to billing the codes, we need to report on the claim who the referring physician is and the last date they saw their primary care physician. This is because if they have a condition that supports medical necessity, they want to know the last time they were seen to monitor that condition. There is a need to ensure that when the appointments are made that this information is collected. You will want to make sure a referral is in the chart for verification. You will also want to review commercial insurance policies as well, since many of them follow Medicare, but they may have billing requirements as well. If you follow all of these instructions, you can be successful in getting paid for medically necessary routine foot care.

Contact for assistance in mitigating risk in your Podiatry services.


Routine Foot Care L35138

Debridement of Mycotic Nails L35013

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