When will you need the Information from Medical Records of In-Person Visit with DPM as it relates to Required Medicare Compliance Documentation for Therapeutic Shoes and Inserts?
Medicare compliance rules can be confusing. A number of different forms must be completed by each of several practitioner who are all required to be part of the process. Fundamental to the program is the assumption that prevention of diabetic wounds can be best prevented when patients have a team approach to their care. As such, the Medicare shoe program requires the participation of, and makes clear the responsibilities of the:
- Prescriber who writes the order (prescription) for therapeutic shoes and inserts.
- Supplier who fits the footwear, and
- Certifying Physician who manages patients’ diabetes care.
Over the past few years, the incidence of Medicare pre-payment reviews and inconsistency of enforcement caused many practitioners to stop fitting shoes. Fortunately, this has ended for the most part. Practitioners are encouraged to identify patients at risk for ulceration and ensure they get fit with the shoes they need.
Here’s a clear explanation of what scenarios necessitate the Information from Medical Records of In-Person Visit with DPM Documenting that Beneficiary has Qualifying Risk Factor(s) for Therapeutic Shoes.
Documents detailed information about the condition (2a-2f listed in the related Policy Article) that qualifies the beneficiary for coverage.
The Certification Statement by itself does not meet this requirement for documentation in the medical records.
The certifying physician must either:
- Personally document one or more of criteria, a – f, in the medical record of an in-person visit within 6 months prior to delivery of the shoes/inserts and prior to or on the same day as signing the certification statement; or
- 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:
- Previous amputation of the other foot, or part of either foot, or
- History of previous foot ulceration of either foot, or
- History of pre-ulcerative calluses of either foot, or
- Peripheral neuropathy with evidence of callus formation of either foot, or
- Foot deformity of either foot, or
- Poor circulation in either foot; and
The “Information from Medical Records of In-Person Visit with DPM Documenting that Beneficiary has Qualifying Risk Factor(s) for Therapeutic Shoes”
- Includes attestation that the certifying physician had an in-person visit with the beneficiary during which diabetes management was addressed and that visit was within 6 months prior to delivery of the shoes/inserts;
- Using the SafeStep WorryFree DME program, the system generates the report based on data entry by supplier.
- Documents MD/DO indication of agreement of qualifying risk factors
Procurement of the signed and dated MD/DO attestation by SafeStep ensures that:
- CMS date and signature requirements are met
- Certifying physician indicates agreement with qualifying conditions prior to or on the same day as signing the certification statement
- The patient is under a comprehensive plan of care for diabetes and that there are chart notes confirming discussion of diabetes management.
In case of an Medicare review; SafeStep will:
- Assist with procurement of supporting chart notes that document discussion of diabetes management with the certifying physician (MD/DO) that is within 6 months of being fit with shoes.
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