“I am trying to educate my physician about the documentation requirements for CPT 11721. He doesn’t think it’s important to document the number of nails debrided or even the method of debridement. Is there a resource you can point me to that specifically addresses this?” This was addressed last week.
“Since it is stated – CPT 11721: Debridement of nail(s) by any method(s); 6 or more, why would it be necessary to document what instruments were used for debridement since any method would be accepted under this description?” This is part 2.
It would be so easy to just say that “they” said so. However, I feel that it is important to identify the sources of information and specifically what is requested as far as the documentation is concerned in order to appropriately address and answer the above 2nd post.
The Medicare Administrative Carrier for the State of Indiana is WPS. Unfortunately WPS does not have an LCD for Debridement of Nails or Nail Debridement. As I have stated multiple times previously, all Medicare Administrative Carriers share information and certainly use this information to aid them in making decisions or determinations regarding billing, coding and of course documentation.
The first Medicare Administrative Carrier in question is Novitas. The LCD in question is L35013 – Debridement of Mycotic Nails. When you access the LCD, under History/Background and/or General Information, it is clearly documented:
“Definitive treatment of mycotic nails involves the appropriate use of effective antifungal pharmacologic agents with or without periodic DEBRIDEMENT of dystrophic nail plates to lessen the fungal load. Medicare will cover debridement of mycotic nails as an adjunct to pharmacologic treatment with a prescription antifungal agent indicated per its Food and Drug Administration (FDA) label for the treatment of fungal nail infections.
DEBRIDEMENT of NAILS, whether by ELECTRIC GRINDER or MANUAL METHOD, is a temporary reduction in the length and thickness (short of avulsion) of an abnormal nail plate. This is usually performed without anesthesia. The debridement code should not be used if the only part of the nail removed is the distal nail border or other portion of nail not attached to the nailbed. Medicare expects debridement services reported for Medicare payment to include removal of maximal nail material possible (in consideration of the clinical condition of the nail and the patient’s degree of comfort during the procedure) required for control of symptoms or infection.”
The second Medicare Administrative Carrier in question is First Coast Service Options. The LCD in question is L33922 – Nail Debridement. When you access the LCD, it is important to then access the associated article A57672 – Billing and Coding: Nail Debridement. Under Documentation Requirements it clearly states:
“1. All documentation must be maintained in the patient’s medical record and made available to the contractor upon request.
2. Every page of the record must be legible and include appropriate patient identification information (e.g., complete name, dates of service[s]). The documentation must include the legible signature of the physician or non-physician practitioner responsible for and providing the care to the patient.
3. The submitted medical record must support the use of the selected ICD-10-CM code(s). The submitted CPT/HCPCS code must describe the service performed.
4. The provider of the service(s) must document the affected nail(s), including the clinical evidence of mycosis, and the MANNER IN WHICH AND TO WHAT EXTENT THE NAIL(S) WERE DEBRIDED. Use of appropriate anti-fungal treatment or the contraindication of such treatment must also be documented. In addition, a description of the qualifying symptoms for debridement of toenail(s) must be documented.”
I never tell people what they should or should not do. However I have now provided two sources of information that requires that the medical record documentation states specifically how the affected toenails were debrided. Is it really that much of a stretch to make sure that the medical record documentation can survive an audit? I don’t think so.
This is my opinion.
Michael G. Warshaw, DPM, CPC
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