08/29/2013    Josh White, DPM

Diabetic Shoe Dispensing (Charles Baik, DPM)

Dr. Hecht's frustration regarding compliance with
the documentation requirements of Medicare's
Therapeutic Shoe Program is understandable and
common. Its unfortunate that a program created
to save Medicare money by preventing ulceration
and amputation while increasing podiatrist income
has fallen into disfavor by many.

I've had the opportunity to poll how commonly
podiatrists have been subject to prepayment
audits in the course of presentations and
webinars I have given on the subject. Certain
regions have been targeted more than others; I
estimate a national prevalence of about 10-15% of
DPMs having received at least one prepayment
audit, with most having received only one though
some have received as many as 30. Clearly, the
vast majority of claims are not audited at all.
Interestingly, the average number of shoes fit by
podiatrists who continue to participate in the
program has continued to increase.

As the president of SafeStep, I've provided
assistance to literally hundreds of offices
who've received audits. The two most common
reasons for podiatrists to have difficulty
complying with documentation requirements have
been demonstration that the patient had been seen
by an MD / DO for management of their diabetes
not more than 6 months prior to when shoes were
fit as well as documentation in the MD / DO
medical records of a qualifying risk factor.
DPMs generally pass audits when the date of the
MD / DO visit for diabetes management has been
attested to and as described in the Medicare LCD,
the DPM has provided the MD/DO with documentation
of their foot exam findings.

In a small percentage of cases, DPMs have failed
prepayment audits and have upon appeal have
needed to present actual chart notes of the
diabetes management visit from the MD. It is not
though required that the MD/DO document podiatric
pathology when shoes are fit by a DPM as it would
be if shoes were fit by a CPed or pharmacist.
This is described in the Local Coverage Article,
May, 2013
https://www.noridianmedicare.com/dme/coverage/docs
/lcds/current_articles/therapeutic_shoes_for_perso
ns_with_diabetes.htm

Obtain, initial, date (prior to signing the
certification statement), and indicate agreement
with information from the medical records of an
in-person visit with a podiatrist, other M.D or
D.O., physician assistant, nurse practitioner, or
clinical nurse specialist that is within 6 months
prior to delivery of the shoes/inserts, and that
documents one of more of criteria a–f.

Look forward in the October issue of Podiatry
Management to an article I've written with step
by step instructions how DPMs in average size
practices can earn $40,000 per year by devoting
only 4 hours per week of staff time to evaluating
patients with diabetes and when appropriate,
fitting for shoes. Shoe fitting and assurance of
Medicare compliance needn't be onerous if tested
protocols are put into place and adhered to.

Josh White, DPM, CPed, President/Founder, SafeStep
joshwhite@safestep.net

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