“I am in practice and would like to figure out a different way to contain and manage my routine foot care. It is approximately 15% of my practice. I would like to designate one morning a week as a routine foot care clinic. I am considering making this a cash only clinic: $50 for toenails and $50 for calluses. Is this possible? I am a Medicare provider and have contracts with most insurance companies. I was hoping to model my cash clinic on what some nurses in the area have done. They visit a nursing home and offer residents $25 for routine foot care and do not work with any insurance companies or Medicare. Any thoughts on this cash model, routine foot care clinic would be appreciated.”
If you had a boutique or a concierge practice or you were not a Medicare provider, either participating or non-participating and did not have to submit a claim for services rendered to the Medicare Administrative Carrier in the state where the practice is located, this would be a wonderful idea. Cash for routine foot care! But, alas, this is not the case as the provider that posted the above scenario IS a Medicare provider and has contracts with most insurance companies.
If the physician in question is a Medicare provider, there is a signed contract with the respective Medicare Administrative Carrier and CMS, the Center for Medicare and Medicaid Services that states that you will follow the rules. One of the rules is that you will appropriately bill the Medicare Administrative Carrier for the service(s) performed on the date of service and documented in the medical record. If the service is a covered service, there is not an option to charge the patient cash for that service, you are obligated to bill the carrier. In the above post, the issue at hand is routine foot care.
Without going into great detail, it is important to know the coverage criteria for “at risk” routine foot care. Of course, it would probably be a good idea to access and READ the LCD of your Medicare Administrative Carrier for routine foot care and the associated article that covers billing and coding for routine foot care. In general, a patient meets the coverage criteria for “at risk” routine foot care if the patient has a covered systemic disease and the class findings that qualify the patient for coverage. If the patient does meet the coverage criteria, the provider must correctly bill the Medicare Administrative Carrier for the service(s) provided on that date of service. If the patient clearly does not meet the coverage criteria, then it would be appropriate to charge the patient cash, out of pocket for the service(s) provided. What do you charge the patient? There are two options. The patient would have to pay out of pocket the amount that you would place on the claim form when the Medicare Administrative Carrier is billed, or the practice has a standard, fixed fee that is charged for non-covered routine foot care.
It is important to note that routine foot care is statutorily NOT COVERED unless the patient meets the coverage criteria as mentioned above. If the patient does not meet the coverage criteria for routine foot care, an Advanced Beneficiary Notice (ABN) of non-coverage is not required. I disagree with this position. I believe that an ABN should be filled out and signed by the patient for ALL non-covered services provided, in this situation for non-covered routine foot care. The reason is that the ABN is the only hard copy proof that the provider has on file that the patient was told what the service is to be provided, why it is not covered and how much the patient has to pay for the service. If there is ever a question by the patient or even the Medicare Administrative Carrier that the patient was never informed that the service is not covered and they had to pay out of pocket, the provider has the signed and dated form that states and shows that the patient was indeed informed in advance.
This is my opinion.
Michael G. Warshaw
THE 2022 Podiatry Coding Manual is now available in either Book or Flashdrive formats. It has been completely updated including the E/M coding changes. Many offices across the country consider this to be their “Bible” when it comes to coding, billing and documentation. The price is still only $125 including shipping! To purchase, access the website drmikethecoder.com.
No credit card? No problem! Just send a check for $125 to the following address:
Dr. Michael G. Warshaw
2027 Bayside Avenue
Mount Dora, FL 32757
Are you in compliance with Medicare concerning your billing, coding and documentation? An audit should never be more than an inconvenience. It should not be a life altering event. Find out your status before you are audited by your Medicare carrier. Drmikethecoder special: Have 5 dates of service audited for $250 (new clients only). Contact drmikethecoder.com for more information.