Diabetic Shoes Update: CMS Publicizes Clarification it Provided to APMA

In February, APMA shared that sustained advocacy and multiple rounds of direct communication with CMS resulted in confirmation that co-signed notes are not required for coverage of diabetic shoes/inserts when other specific documentation standards are met.

Now, following APMA's request, CMS publicized that clarification with an article that emphasized the two options and separates these two options with a capital "OR," making it clear that there is an alternative to the co-signed notes.

Specifically, CMS clarified that there are two options for the certifying physician to meet the documentation requirements for establishing the presence of the qualifying condition(s).

1. 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

1. 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 a - f.

Auditors have routinely and inappropriately required both personal documentation by the certifying physician in their own medical records in addition to co-signed notes of the podiatrist or other physician or practitioner. When both are not satisfied, podiatrists report that auditors have denied coverage and recouped payment, and this clarification from CMS is critical to reducing burdens with unnecessary paperwork for physicians and patients.

APMA continues to work with CMS to provide education to auditors, physicians, and other stakeholders on this important clarification. Contact the APMA Advocacy Department with any questions at [email protected].