LCD L35138: Routine Foot Care

Notice: It is not appropriate to bill Medicare for services that are not covered (as described by this entire LCD) as if they are covered. When billing for non-covered services, use the appropriate modifier.

Compliance with the provisions in this policy may be monitored and addressed through post payment data analysis and subsequent medical review audits.

The Medicare program generally does not cover routine foot care. However, CMS IOM Publication 100-02, Medicare Benefit Policy Manual , Chapter 15, Section 290 Foot Care outlines complete coverage details and the specific conditions for which coverage may be present.

Indications

Please refer to CMS IOM Publication 100-02, Medicare Benefit Policy Manual , Chapter 15, Section 290 B 2 Routine Foot Care for a list of services that are generally considered components of routine foot care.

In addition to those services listed in the above manual, the following services are considered to be components of routine foot care, regardless of the provider rendering the service:

• Cutting or removal of corns and calluses

• Clipping, trimming, or debridement of nails

• Shaving, paring, cutting or removal of keratoma, tyloma, and heloma

• Non-definitive simple, palliative treatments like shaving or paring of plantar warts which do not require thermal or chemical cautery and curettage;

While the Medicare program generally excludes routine foot care services from coverage, there are specific indications or exceptions under which there are program benefits. Please refer to CMS IOM Publication 100-02, Medicare Benefit Policy Manual , Chapter 15, Section 290 C for information on exceptions to routine foot care exclusion.

Note: Information on the potential coverage and billing for those diabetic patients with severe peripheral neuropathy involving the feet, but without vascular impairment (LOPS), may be found at: Medicare National Coverage Determinations Manual -Pub. 100-03, Chapter 1, Section 70.2.1 and Medicare Claims Processing Manual -Pub. 100-04, Chapter 32, Sections 80-80.8.

CMS IOM Publication 100-02, Medicare Benefit Policy Manual , Chapter 15, Section 290 D lists systemic conditions that may justify coverage for routine foot care. In addition to those listed in the manual, the following conditions represent systemic conditions that may result in the need for routine foot care:

• Amyotrophic Lateral Sclerosis (ALS)

• Arteritis of the feet

• Chronic indurated cellulitis

• Chronic venous insufficiency

• Intractable edema-secondary to a specific disease (e.g., congestive heart failure, kidney disease, hypothyroidism)

• Lymphedema-secondary to a specific disease (e.g., Milroy's disease, malignancy)

• Peripheral vascular disease

• Raynaud's disease

Claims indicating other diagnoses not specified above will be denied unless the medical record documentation is submitted with the claim.

Limitations

• When the patient's condition is designated by an ICD-10-CM code with an asterisk (*) (see ICD-10-CM Codes in the Local Coverage Article: Billing and Coding: Routine Foot Care [A52996]), routine foot care procedures are reimbursable only if the patient is under the active care of a doctor of medicine or osteopathy (MD or DO) or NPP 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 or if the patient had come under a physician’s or NPPS care shortly after the services were furnished.

• Routine foot care should not be paid in the absence of convincing evidence that non-professional performance of the service would be hazardous for the patient because of an underlying systemic disease.

• Evaluation and management (E/M) services for any of the conditions defined as routine foot care will be considered ineligible for reimbursement, with the exception of the initial E/M service performed to diagnose the patient’s condition.

• Evaluation and management (E/M) services provided on the same day as routine foot care by the same doctor for the same condition are not eligible for payment except if it is the initial E/M service performed to diagnose the patient's condition or if the E/M service is a significant separately identifiable service indicated by the use of modifier 25, and documented by medical records.

• Additionally, whirlpool treatment performed prior to routine foot care to soften the nails or skin is not eligible for separate reimbursement.

This LCD imposes frequency limitations. For frequency limitations, please refer to the Utilization Guidelines section below.

The redetermination process may be utilized for consideration of services performed outside of the reasonable and necessary requirements in this LCD.

Notice: Services performed for any given diagnosis must meet all of the indications and limitations stated in this policy, the general requirements for medical necessity as stated in CMS payment policy manuals, any and all existing CMS national coverage determinations, and all Medicare payment rules. Please refer to the Local Coverage Article: Billing and Coding: Routine Foot Care (A52996) for applicable CPT and diagnosis codes.

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