05/31/2023    Paul Kesselman, DPM

How are NPs and PAs Involved in Diabetic Shoe Documentation ( Edmond F Mertzenich, DPM)

CMS attempts to facilitate access for therapeutic
shoes to patient who only see PA or an NP has been
a flop. It also has confused the auditors at every
level, created a larger paperwork trail and even my
fellow DME council members continue to flood
my phone and email box just having reviewed this
issue during a council meeting. So to try and give
a straight answer covering every scenario in this
format would be near impossible. This is what a PA
can do:

If you are the supplier and prescriber:
They (the PA) can perform a systems exam, sign the
supervising physician statement and attest
agreement with your notes. However, every single
one of those documents must be co signed and dated
by the MD DO supervising the diabetes. And
everything must conform to every other standard
documentation requirement and date requirements of
the policy.

The same is true for the NP if they are working
under the supervision of an MD DO as is required by
their state law or if they are working incident to
an MD DO.

If they are in a state where the NP is practicing
totally independent of an MD or DO this is where
things get even dicier and more confusing:

There is a program called the Primary Care First
Initiative (PCFI) in select locations in certain
states. If and only if the NP is seeing patients
independent of an MD DO AND if they are enrolled in
the PCFI AND seeing the patient through the PCFI
program ONLY then can they act wholly independent
and perform all the functions of a Supervising MD
DO.

To find this latter information about the PCFI
program to determine if the NP is in fact enrolled
in this program and seeing your patient in the PCFI
- Well good luck! CMS has a website for the PCFI
which is far from user friendly.

If the NP is practicing independently but not
enrolled in the PCFI or not seeing patients in a
location not designated as PCFI see PA situation .

As I said from the onset of this response the gov’t
has found a way to make easier access way more
convoluted and even more susceptible to audit
failure. And you wonder why more suppliers of every
discipline are abandoning this program?

Paul Kesselman, DPM, Oceanside, NY

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