“On all of our patients that qualify for routine foot care with the diagnosis of I70.203 Atherosclerosis we send an “Atherosclerosis Letter” to the patient’s treating doctor with our findings and ask them to sign if they agree with our findings. 99% of the time the doctors send the letter back signed. We have always done this in accordance with the routine foot care LCD that in the past stated that we had that letter or documentation from the treating physician in our patient’s chart “in a timely manner.” Recently we have had some doctors sending back the letter, disagreeing with our findings. We have already billed the services from their initial visit knowing or thinking that we will have that documentation for the next appointment in 9 weeks. This led me to research the LCD again, and I am unable to locate the verbiage that was used before about the patient’s other treating doctors agreeing and signing anything. It merely states that we have our findings in the note and the other doctor’s name on the claim to Medicare. Do we need that letter agreed to and signed from the patient’s other doctor? Do other offices also send this “letter” to get that info? Any input is greatly appreciated.”
When it comes to “At Risk,” Routine Foot Care (RFC), there are two groups of systemic disease entities that provide coverage. They are the Asterisk (*) and the Non-Asterisk Systemic diseases.
Asterisk Systemic Diseases:
Patients with one of these diseases must be under the Active Care of an MD or DO or a non-physician practitioner (NP, PA). Active care means that the MD or DO is treating the patient for that specific disease and has been seen at least once in the past 6 months for that disease prior to the foot care encounter. This is referred to as the Active Care Requirement.
Non-Asterisk Systemic Diseases:
A systemic disease that does not have a Medicare asterisk designation has different requirements for record keeping and billing. The systemic disease diagnosis and subsequent treatment of that systemic disease can be made by an MD or DO as appropriate. It is necessary to have adequate medical record documentation to support the diagnosis making decision… and subsequent treatment. The simple indication of a systemic diagnosis without documentation is not adequate. Please note that since DPM’s are limited scope practitioners, a DPM cannot treat a systemic disease. A DPM can treat the manifestations, complications, or end results of a systemic disease when they appear in the treating area of a DPM, the foot and the ankle. The date last seen is NOT a requirement for the non-asterisk systemic diseases. When the LCDs for RFC are accessed, ICD-10-CM code I70.203 – Unspecified atherosclerosis of native arteries of extremities, bilateral legs is classified as a non-asterisk systemic disease. Please confirm by reading your Medicare Administrative Carrier’s LCD for RFC.
Taking into consideration that the patient in the above post was treated in the state of Florida, I accessed the First Coast Service Options LCD L33941 – Routine Foot Care and the associated article A57188 – Billing and Coding: Routine Foot Care. In the state of Florida, it is no longer a requirement on claims submitted by a podiatrist that the name of the MD, DO, or non-physician practitioner who diagnosed the complicating condition must be present on the claim form. Thanks to Mark Block, DPM, the most updated version of the LCD and the associated article states the following: “On all claims submitted by a podiatrist with ICD-10-CM diagnosis codes with non-asterisked conditions, the name of the M.D., D.O., or non-physician practitioner (PA or NP) or the podiatrist who diagnosed the complicating condition must be on the claim form.” Therefore, in the state of Florida, it is not necessary to have a signed letter by the physician or non-physician practitioner to support the diagnosis for the systemic disease qualifying the patient for “At Risk” Routine Foot Care.
What about the other states? It is imperative to go on the website of your Medicare Administrative Carrier and access the LCD and the associated article for RFC and follow the guidelines and the rules for non-asterisk systemic diseases. If your Medicare Administrative Carrier does not have an LCD for RFC, I would suggest accessing the Medicare Benefits Policy Manual, Chapter 15, Section 290, Foot Care.
This is my opinion.
Michael G. Warshaw
DPM, CPC
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