03/01/2016    Joseph Borreggine, DPM

NPs and PAs Providing Comprehensive Diabetic Exams

The recent MAC National Government Service (NGS)
DMEPOS Webinar held 2-25-2016 titled "APMA Lunch
and Learn Webinar Series" clarified a couple of
points when a DPM (physician supplier or
supplier) provides/dispenses qualified diabetic
patients with therapeutic shoes/inserts.

Today, according to the NGS webinar presenters,
PAs and NPs cannot perform the required diabetic
comprehensive exam (DCE) on that diabetic needing
shoes. This DCE is supposed to occur on that
patient no less than six months prior to
receiving diabetic shoes and inserts . CMS policy
states that NPs and PAs are not defined as a
"certifying physician". MDs/DOs are only defined
as a "certifying physician".

Hence based on this policy, even though the NP or
the PA may be the diabetic patient's only primary
care provider, they cannot perform the DCE. This
DCE must and can only be performed by the MD/DO.
The NP or PA cannot perform the DCE and have the
MD/DO countersign as the "supervising physician".
Therefore, according the CMS DMEPOS policy, a
MD/DO (who may have never seen that diabetic
patient who may need diabetic shoes/inserts) must
and can only see that diabetic patient face-to-
face and perform the DCE for that patient.

This policy may be disconcerting to the
"physician supplier", i.e., the DPM, who
practices in a rural area or has a patient who
only sees a NP or PA for there diabetic
management. This may limit patient access to
diabetic shoes/inserts for those diabetics who
require or need them. However, if that DPM
practices in area considered by CMS as a "Health
Manpower Shortage Area", then the podiatrist may
be defined as the "certifying physician" and
perform the the required DCE.

Also, according to CMS DMEPOS policy and it is my
understanding according to the presenters at the
webinar: When a DPM is dispensing diabetic shoes
and inserts to a qualifying patient in the
office, the DPM is defined as the "physician
supplier" may not allow their medical assistant
to perform the fitting of the shoes since they
are not qualified to do so and are not defined as
the "supplier" of said DME items.

Joseph Borreggine, DPM, Charleston, IL

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