“If a patient has a statement of certifying physicians from their doctor and the note from the MD/PCP that was sent to us, do we still need to have them sign an agreement with the podiatrist’s notes also, or will the MD/PCP notes and the statement suffice for Medicare? If you can please advise me, I would appreciate it. We cannot find information on that specific situation on the Medicare/Noridian DME site.”
The OIG’s current oversight strategy operates on a rolling update model. A dedicated active audit project titled "Medicare Payments to Suppliers for Therapeutic Shoes for Enrollees with Diabetes" (Project Number OAS-26-09-070) was launched to explicitly analyze payments and enforcement moving forward. This directly targets podiatrists who prescribe, order, or act as suppliers for diabetic footwear.
When the OIG or its contractors audit podiatric suppliers under this work plan item, they focus on specific technical pitfalls:
The Multi-Doctor Paperwork Gap: A podiatrist can order or dispense the shoes, but Medicare law dictates that the patient’s managing MD or DO (the physician treating the systemic diabetes) must explicitly certify the need for therapeutic footwear. A major cause of recoupment is failing to have the managing MD/DO’s diabetes treatment notes within six months prior to delivery in the supplier's file.
Missing Qualifying Foot Conditions: The clinical notes must clearly confirm that the patient suffers from diabetes plus at least one severe secondary condition: peripheral neuropathy with evidence of callus formation, history of pre-ulcerative calluses, previous foot ulceration, past amputation, poor circulation, or foot deformity.
Implicit Timing Rules: Audits frequently target the lag time between the certifying physician's evaluation, the podiatrist's standard written order (SWO), and the physical delivery date.
Recent CMS Clarifications (Co-Signed Notes): Following extensive pushback from the American Podiatric Medical Association (APMA), CMS publicized a key clarification that co-signed notes are not strictly required to satisfy the criteria, provided alternative documentation explicitly establishing the managing physician’s plan of care is present. OIG auditors will be verifying compliance with these exact updated standards.
This is my opinion.
Michael G. Warshaw, DPM, CPC
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