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08/30/2013 Paul Kesselman, DPM
Diabetic Shoe Dispensing (Neil Hecht, DPM)
I could not agree more with Neil. There are a few stronger Yiddish words my grandparents taught me, but I promised never to use them in public. Despite what the carrier medical directors (CMDs) have done in an attempt to destroy this program, it is enlightening to know that even the Medicare carriers can't agree on how many claims are audited and how many are either rejected on post payment audit or is required to be refunded on post payment audit. A difference from 93 to 97% is not that statistically different. But one from 93% low side on one study to 33% high side on another is certainly staggering. If the gov't wizards can't agree, what are we to think.
The original thread here suggested that keeping a copy of the date that patient last saw the MD/DO or have him sign your note with that information would be adequate. I only wish that were true.
It is mandatory to have a copy of the MD/DO's record from a face to face encounter with the patient within 6 months of the date of shoe delivery. This is the number one issue and one which cannot be defended in its absence during an audit.
While I don't agree with its presence by the policy makers, the interpretation by the CMDs or the ALJs, it nevertheless is required. The absence of podiatric notes, orders, certification statements are usually not true and are due to a lack of proper diligence on the part of the auditors.
If your patients truly want to obtain this benefit, they must be educated (as must the MD/DO) that they are an integral part of the process.
As for fears of audits, I'm more concerned about the absurd regulations and documentations with at risk foot care. One podiatrist suggested that the tense of the word debridement could make all the difference in the world. So if you truly are fearful of surviving a gov't audit, why not just stop taking Medicare altogether? Paul Kesselman, DPM, Woodside, NY, drkesselmandpm1@hotmail.com
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