Billing and Coding: Routine Foot Care

This Billing and Coding Article provides billing and coding guidance for Local
Coverage Determination (LCD) L33941 Routine Foot Care. Please refer to the LCD
for reasonable and necessary requirements.

**Coding Guidance**

**Notice:** It is not appropriate to bill Medicare for services that are not
covered (as described by the entire LCD) as if they are covered. When billing
for non-covered services, use the appropriate modifier.

In order for routine foot care to be a covered service, the patient must have
one or more of the diagnoses listed under the "ICD-10 Codes that Support
Medical Necessity" section. Otherwise, the service is noncovered and should be
coded with a GY modifier (Item or service statutorily excluded or does not
meet the definition of any Medicare benefit).

An evaluation and management visit will be paid on the same day as routine
foot care only if the visit was medically necessary and was for a significant,
separately identifiable service, and the modifier -25 is used.

For the treatment of mycotic nails, please refer to the LCD L33922 Nail
Debridement for indications and limitations.

On all claims submitted by a podiatrist with ICD-10-CM diagnosis codes
containing an asterisk on the tables below, the name of the M.D., D.O., or
non-physician practitioner (PA or NP) who diagnosed the complicating condition
must be submitted with the claim. The approximate date the beneficiary was
last seen by the physician/ non-physician practitioner must also be indicated.

On all claims submitted by a podiatrist with ICD-10-CM diagnosis codes with
non-asterisked conditions, the name of the M.D., D.O., or non-physician
practitioner (PA or NP) or the podiatrist who diagnosed the complicating
condition must be on the claim form.

For all providers submitting claims for routine foot care with ICD-10-CM
diagnosis codes in the "Group 2 Codes" table below, the claims should use the
appropriate modifiers (Q7, Q8, or Q9) to indicate the findings the provider
has made on the patient's condition.

  * Q7 = One Class A finding
  * Q8 = Two Class B findings
  * Q9 = One Class B and two Class C findings

Class A Findings

  * Nontraumatic amputation of foot or integral skeletal portion thereof

Class B Findings

  * Absent posterior tibial pulse, or
  * Absent dorsalis pedal pulse, or
  * Three of the following advanced tropic changes are required to meet one class B finding:
    * Hair growth (decrease or absence)
    * Pigmentary changes (discoloration)
    * Skin color (rubor and redness)
    * Nail changes (thickening)
    * Skin texture (thin, shiny)

Class C Findings

  * Claudication (pain in calf when walking)
  * Temperature changes in the feet (e.g., cold feet)
  * Edema
  * Parathesias (abnormal spontaneous sensations in the feet, e.g., tingling)
  * Burning

For patients with peripheral neuropathy involving the feet but without
vascular impairment, claims would be submitted without the Q7, Q8, or Q9
modifiers. Use the ICD-10-CM diagnosis codes in the "Group 3 Codes" table
below.

For patients requiring anticoagulation therapy, use the ICD-10-CM diagnosis
codes in the "Group 4 Codes" table below.

**Documentation Requirements**

  1. All documentation must be maintained in the patient's medical record and made available to the contractor upon request.
  2. Every page of the record must be legible and include appropriate patient identification information (e.g., complete name, dates of service[s]). The documentation must include the legible signature of the physician or non-physician practitioner responsible for and providing the care to the patient.
  3. The submitted medical record must support the use of the selected ICD-10-CM code(s). The submitted CPT/HCPCS code must describe the service performed.
  4. When a Q7, Q8, or Q9 modifier is used, the provider must document in the medical record the appropriate signs and symptoms as outlined in Class Findings A, B, and/or C along with the complicating condition(s).
  5. When the patient has a systemic condition that might justify coverage and the services are performed by a podiatrist, the medical record must contain the name of the treating and/or diagnosing doctor of medicine or osteopathy. 
  6. For diagnoses of peripheral neuropathy that do not require a Q modifier, and the presumption of coverage is based on loss of protective sensation, documentation must be available in the medical record of an absence of sensation at two or more sites out of five tested on either foot when tested with the 5.07 Semmes-Weinstein monofilament to support the diagnosis of peripheral neuropathy with loss of protective sensation. This test may be performed by the attending physician, non-physician practitioner, or the podiatrist.
  7. For patients requiring anticoagulation therapy, the provider must document in the medical record the significant risk and danger posed by the non-professional rendering routine foot care services.