Don’t let this be you!
The Program
Medicare’s “Therapeutic Shoes for Persons with Diabetes” program is a phenomenal benefit to patients, with a robust library of peer-reviewed literature supporting the fact that these therapeutic shoes / inserts decrease pathology and prevent complications in patients with diabetes, leading to improved outcomes for our practices. Just like every other service we provide, there are compliance guidelines that must be followed when participating in this program. Fortunately, when it comes to this service of therapeutic shoes and inserts, these requirements are publicly available and published online (1,2).
The Rule
In addition to publishing the requirements, the most commonly committed compliance errors associated with this program are also published (3). Reviewing this list allows providers to ensure they are not committing any of these errors. The top three errors on this list consistently involve the documentation requirements associated with supplying therapeutic shoes / inserts.
Two required documents associated with this program are the Statement of Certifying Physician for Therapeutic Shoes and the Documentation of Medical Necessity. The Statement of Certifying Physician for Therapeutic Shoes form must be completed by the MD or DO who is managing the patient’s diabetes and must state that:
- The patient has diabetes
- The patient has one or more of the conditions required for coverage of therapeutic shoes and inserts
- The patient is under the active management of that MD or DO for diabetes
- The provider’s certification that the therapeutic shoes / inserts are medically necessary for that patient.
The Documentation of Medical Necessity form must contain:
- A complete lower extremity exam,
- Documentation that the patient has one or more of the conditions required for coverage of therapeutic shoes and inserts
- And that therapeutic shoes / inserts are medically necessary for that patient
This Documentation of Medical Necessity form may be completed by the prescribing physician, must be signed by the MD or DO who is managing the patient’s diabetes, and must be returned to the prescribing physician.
#1 Error
One Medicare Contractor reports that during the final calendar quarter of 2023, the #1 error committed in submitting payment claims for therapeutic shoes/inserts was the Documentation of Medical Necessity form was either not completed at all, did contain the required complete lower extremity exam, or was completed but was not signed by the MD or DO who is managing the patient’s diabetes.
In many cases, the supplying provider completed the form and sent it to the MD or DO who was managing the patient’s diabetes, but the form was never returned to the supplying provider. This is one error that can be avoided when aligning with SureFit® for the provision of therapeutic shoes/inserts.
SureFit provides its customers with its Medicare Document Management (MDM) System. Through this system, SureFit helps its customers ensure that all documentation related to supplying therapeutic shoes/inserts is complete and compliant. As it relates to this #1 error, SureFit will help ensure the Documentation of Medical Necessity form is complete and signed by the MD or DO managing the patient’s diabetes before dispensing takes place, thereby not allowing their customers to commit error #1.
#2 Error
The second most common error in this report was failure to include the Statement of Certifying Physician for Therapeutic Shoes form, which is described above. This must include documentation of that provider’s management of the patient’s diabetes. In some cases, the form and its accompanying documentation are completed by the MD or DO managing the patient’s diabetes, but there is no discussion of that MD / DO managing the patient’s diabetes in the documentation shared. This is yet another screening performed by SureFit with its MDM program. Not only does SureFit ensure the required documentation is present, but they also ensure it contains what is required.
#3 Error
The third most common error reported was that the supplying provider’s documentation did not contain any medical records at all from the MD or DO managing the patient’s diabetes. The required medical records from the MD or DO managing the patient’s diabetes are detailed above, and not having any of them at all is a critical error. This will not happen for those who are engaged with SureFit and their MDM program.
Conclusion
Medicare’s Therapeutic Shoes for Persons with Diabetes program helps us to serve our communities, fulfill our oaths, and achieve excellent outcomes. Payer requirements should not discourage us from participation. Instead, knowledge of these requirements should only motivate us to learn the rules, follow the rules, avoid errors, and partner with entities like SureFit that help us to succeed.
Shop the SureFit Online Store today for lower extremity solutions, diagnostic equipment, and more!
About the Author
Jeffrey D. Lehrman, DPM, FASPS, MAPWCA, CPC, CEMC, CPMA is a podiatrist practicing in Fort Collins, CO and operates Lehrman Consulting, LLC which provides guidance regarding coding, compliance, and documentation. Dr. Lehrman is a Certified Professional Coder and Certified Professional Medical Auditor.
