What is required in the Statement of the Certifying Physician 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 practitioners 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 mostly ended. 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 the required Statement of the Certifying Physician:
The certifying physician must be an M.D. or D.O and may not be a podiatrist, physician assistant, nurse practitioner, or clinical nurse specialist. The “Statement of Certifying Physician for Therapeutic Shoes” must be completed, signed, and dated by the certifying physician. A new Certification Statement is required for a shoe, insert or modification provided more than one year from the most recent Certification Statement on file.
The certifying physician certifies that: The beneficiary has diabetes mellitus and that he/she is treating the beneficiary under a comprehensive plan of care for his/her diabetes, that the beneficiary needs diabetic shoes and demonstrates one or more of the following conditions:
- 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 certifying physician must:
- Sign the certification statement (refer to the Documentation Requirements section of the related Local Coverage Determination) on or after the date of the in-person visit and within 3 months prior to delivery of the shoes/inserts.
- Indicate when the patient was most recently seen for management of their diabetes. Coverage for shoes requires it to be no more than six month prior to when the shoes are fit.
- Certifies patient has diabetes mellitus and that the patient has qualifying conditions.
- Must be signed either at the same time or after indicating agreement with podiatrist’s chart notes documenting the qualifying conditions.
Procurement by SafeStep ensures that:
- CMS date and signature requirements are met
- The certifying physician indicates agreement with qualifying conditions prior to or on the same day as signing the certification statement
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