Due to prior OIG work identifying inappropriate payments for podiatrists and ancillary services, the OIG announced in Feb 2019 they will begin a new review starting in 2020. The OIG stated they will review Medicare Part B payments to determine if medical necessity is supported in accordance with Medicare requirements.
Part of the OIG’s review and attention will include ancillary services reported in the Podiatrist practice. To better treat patients, improve outcomes and their bottom line, more and more podiatrists are adding ancillary services to their practices. If you plan on adding ancillary services or are currently reporting these services, be sure you have the appropriate knowledge and understanding. A great source for information and documentation can be found in your Local Coverage Determinations (LCDs) from your Medicare carrier. Also, don’t forget your commercial payer policies and rules. Referring to your LCDs and payer policies is vital to ensure compliance with the medical necessity behind ancillary services like X-Rays, nerve conduction testing, ultrasounds, vascular testing, and physical therapy.
Be sure all services are supported by medical necessity and documentation!
There are also a lot of exclusions for Podiatrists when treating a patient for foot care, such as debridement, trimming, clipping toenails and removing corns and calluses. However, Medicare Part B may cover medical conditions that are medically necessary such as foot injuries and patients’ foot care with the presence of certain systemic diseases. For rules on Podiatry services and conditions that might justify coverage review, see Medicare’s Fact Sheet and your local Local Coverage Determination (LCD). The OIG also mentioned they will be looking at E/M services as Medicare will not cover an E/M service that is provided on the same day as foot care unless it is a significant separately identifiable service.