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The OIG Adds Podiatry Services to Their Work Plan

The OIG Adds Podiatry Services to Their Work Plan February 26, 2019
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The OIG recently added podiatry and related ancillary services to their Work Plan.

While routine podiatry services like nail trimming and callus/corn removal are generally not covered by Medicare Part B, some medically necessary services may be covered if they meet one of the following exceptions:

  • Performed as a necessary and integral part of otherwise covered services, such as diagnosis and treatment of ulcers, wounds or infections
  • Mycotic nails (toenail infections)
  • Treatment of foot warts
  • Performed in the presence of another systemic condition(s) such as diabetes

In addition, evaluation and management services (E/M) are generally not covered the same day as other podiatry services UNLESS the E/M service is a significant, separately identifiable service above and beyond the routine evaluation that is included in the podiatry service being performed. 

The OIG is also looking at ancillary services ordered by podiatrists (labs, x-rays, prescription drugs and therapy) which are permitted as long as the service is deemed medically necessary. 

Prior findings of inappropriate payments for these types of services has led the OIG to add podiatry to the current Work Plan.  The OIG will specifically review Part B payments to determine whether podiatry and ancillary services were medically necessary and provided in accordance with Medicare requirements.

CMS has issued a helpful Fact Sheet regarding podiatry services that can be can be accessed here:  https://www.cms.gov/Outreach-and-Education/Medicare-Learning-Network-MLN/MLNProducts/Downloads/MedicarePodiatryServicesSE_FactSheet.pdf

Chapter 15 of the Medicare Benefit Policy Manual also outlines coverage criteria and the details can be found here at section 290:  https://www.cms.gov/Regulations-and-Guidance/Guidance/Manuals/downloads/bp102c15.pdf

We recommend you review the Work Plan and conduct proactive audits of identified known risks that are applicable to your organization.  HBE’s team of experts is available to assist you with these audits and any necessary education and training.

The OIG Work Plan can be found at:  https://oig.hhs.gov/reports-and-publications/workplan/updates.asp

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