ROUTINE FOOT CARE - Chronic Kidney Disease

“Any thoughts on whether ICD-10-CM codes N18.1-N18.6 (chronic kidney disease) are “asterisk” covered diagnoses’ for nail and callus codes? I practice in Illinois. If so, are the date of last service and a Q modifier all that are needed?“

The Medicare Administrative Contractor for the state of Illinois is National Government Services (NGS). In order to understand the requirements for “At Risk,” Routine Foot Care (RFC), it is important to access the NGS website and find the Local Coverage Determination (LCD) for RFC. The LCD L33636 is entitled “Routine Foot Care and the Debridement of Nails.” It is also important to access the associated Article A57759 “Billing and Coding: Routine Foot Care and the Debridement of Nails.”

When the list of covered systemic diseases is found within Article A57759, specifically listed under “ICD-10-CM Codes that Support Medical Necessity, Group 1 Codes,” ICD-10-CM codes N18.1 – N18.6 are present. They are all appended by an asterisk. At the end of this specific list of systemic diseases is the following statement:
“Group 1 Medical Necessity ICD-10-CM Codes Asterisk Explanation:
* For these diagnoses, the patient must be under the active care of a doctor of medicine or osteopathy (MD or DO) for the treatment and/or evaluation of the complicating disease process during the six (6) month period prior to the rendition of the routine-type service.”

What specifically is an asterisk systemic disease?
An “Asterisk” systemic disease simply refers to a disease that Medicare designates the necessity for an MD or DO physician to make the diagnosis and actively treat the patient for that disease. Actively means that the patient has to have been seen by the MD or DO within a 6 month period for that specific disease. This is referred to as the “Active Care Requirement.” When a podiatrist provides a RFC service (CPT 11055, CPT 11056, CPT 11057, CPT 11719, CPT 11720, CPT 11721 or G0127) to a patient with an “asterisk” systemic disease they can bill and be paid by Medicare, but must include specific information in their medical record.

Include the following in your medical record: 

1. The treating MD or DO’s name.
2. The date last seen by the MD or DO.
3. The specific systemic disease
4. The associated complication(s) resulting from the disease (These are the Class Findings that lead you to select the appropriate Q modifier to append to the CPT codes that are being billed
5. The documentation for the podiatric diagnosis(es) including treatment plan

Include the following on the billing claim form:

1. The name of the MD or DO treating the systemic disease
2. The NPI of the MD or DO treating the systemic disease
3. The date last seen by the MD or DO specifically for the systemic disease (Day/Month/Year)
4. The systemic disease (ICD-10-CM) code of the treating MD or DO
5. The DPM’s podiatric diagnosis(es) (ICD-10-CM) code(s)
6. The appropriate CPT code(s): 11055, 11056, 11057, 11719, 11720, 11721, G0127 appended by the correct Q modifier (Q7, Q8, Q9)
7. The Q modifiers are documented in the medical record as the associated complications resulting from the systemic disease. These are the Class Findings.

This is my opinion.

Michael G. Warshaw, DPM, CPC

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