01/31/2024    Kristin Happel

Foot Care for Medicare Hospice Patients (Cary Wolf, DPM)

I am wondering if Dr. Wolf and his colleagues are
possibly misinterpreting what their CBR's say, and
what the purpose of a competitive billing report (CBR)
is. I bill for a mobile
podiatry practice in PA, and they also recently
received a CBR from their MAC concerning the amount
of hospice patients they are treating. Nowhere in
the CBR did it say that there would be limits
placed on anything, including reimbursement. I
explained to the doctors how CBRs are generated and
what they mean, and that it was not surprising they
received one, due to the sheer amount of patients
they seen on hospice compared to other practices in
PA.

But under no circumstances were they doing anything
wrong, and they should continue billing as they
always have. It is just part and parcel of being a
mobile podiatry practice. You are seeing patients
in their homes, in SNFs, in ALFs, and in adult day
care. Those places are always going to skew higher
with having patients on hospice. While mobile
podiatry practice I bill for may see 25 or more
patients a month on hospice, the 3 other office-
based practices I also bill for may see 1 or 2 a
month, IF that.

So guess who is going to get sent a CBR for being
an "outlier" when it comes to using the GW
modifier? I would encourage Dr. Wolf and his
colleagues to reread their CBR's. I have read many
of these over the years, and none of them have ever
said in effect: "You can only bill this code or add
this modifier X amount of times, and we will also
restrict your reimbursement while we are at it".
All they are telling you is how you rank versus
other podiatrists in your state/on a national level
when it comes to billing certain codes and
modifiers, because they want you to be aware you
are an "outlier".

What they do NOT take into consideration is the
type of practice you have. If what you are doing
meets the requirements of medically necessary foot
care, as stated in your MAC's LCD, there should not
be an issue here. While it is possible I am
completely off-base here, I don't think that I am,
based on the CBR I just read for this very same
issue, and all of the CBRs I have read in the past.

Kristin Happel, Podiatry Biller, Chicago, IL

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