Reporting Periods for 2011
For 2011, there are both six-month and 12-month reporting periods available. For claims-based and registry-based reporting, providers may either report from January 1 through December 31, or July 1 through December 31. For EHR-based reporting, providers must report over the course of the 2011 calendar year, that is, January 1 through December 31.
Once claims have been submitted, CMS will analyze them to verify satisfactory reporting during the entire reporting period. If an eligible professional is deemed to have reported successfully, CMS will calculate the appropriate incentive payment and distribute bonus payment checks in the spring of 2012.
Eligible professionals who successfully report will receive an incentive bonus of 1% of all the practitioner’s charges for Medicare Part B covered professional services (not just claims for which quality data were submitted) for the 2011 reporting period. An incentive payment of 0.5% will be paid for successful participation in PQRS for 2012, 2013, and 2014.
ADA (2004) recommends that all individuals with diabetes should receive an annual foot examination to identify high-risk foot conditions. This examination should include assessment of protective sensation, foot structure and biomechanics, vascular status, and skin integrity.
The ADA (2004) recommends that people with one or more high-risk foot conditions should be evaluated more frequently for the development of additional risk factors. People with neuropathy should have a visual inspection of their feet at every contact with a health care professional.
Measure #126: Diabetes Mellitus: Diabetic Foot and Ankle Care, Peripheral Neuropathy – Neurological Evaluation
Percentage of patients aged 18 years and older with a diagnosis of diabetes mellitus who were evaluated for proper footwear and sizing
This measure is to report a minimum of once per reporting period for patients with diabetes mellitus seen during the reporting period. Evaluation of neurological status in patients with diabetes to assign risk category and therefore have appropriate foot and ankle care to prevent ulcerations and infections ultimately reduces the number and severity of amputations that occur. Risk categorization and follow up treatment plan should be done according to the following table:
Risk Categorization System:
|Category||Risk Profile||Evaluation Frequency|
|1||Peripheral Neuropathy (LOPS)||Semi-annual|
|2||Neuropathy, deformity, and/or PAD||Quarterly|
|3||Previous ulcer or amputation||Monthly to quarterly|
This measure may be reported by non-MD/DO clinicians who perform the quality actions described in the measure based on the services provided and the measure-specific denominator coding.
Lower Extremity Neurological Exam – Consists of a documented evaluation of motor and sensory abilities including reflexes, vibratory, proprioception, sharp/dull and 5.07 filament detection.
Lower Extremity Neurological Exam Performed
G8404: Lower extremity neurological exam performed and documented
Measure #127: Diabetes Mellitus: Diabetic Foot and Ankle Care, Ulcer Prevention – Evaluation of Footwear
Percentage of patients aged 18 years and older with a diagnosis of diabetes mellitus who were evaluated for proper footwear and sizing
This measure is to report a minimum of once per reporting period for patients with diabetes mellitus seen during the reporting period. This measure may be reported by non-MD/DO clinicians who perform the quality actions described in the measure based on the services provided and the measure-specific denominator coding.
Evaluation for Proper Footwear – Includes a foot examination documenting the vascular, neurological, dermatological, and structural/biomechanical findings. The foot should be measured using a standard measuring device and counseling on appropriate footwear should be based on risk categorization.
Footwear Evaluation Performed
G8410: Footwear evaluation performed and documented
Measure #163: Diabetes Mellitus: Foot Exam
This measure is to be reported a minimum of once per reporting period for patients with diabetes mellitus seen during the reporting period. The performance period for this measure is 12 months. This measure may be reported by clinicians who perform the quality actions described in the measure based on the services provided and the measure-specific denominator coding.
The percentage of patients aged 18 through 75 years with diabetes who had a foot examination
Foot Exam Performed
CPT II 2028F: Foot examination performed (includes examination through visual inspection, sensory exam with monofilament, and pulse exam – report when any of the three components are completed)
Medicare’s Pricing, Data Analysis and Coding (PDAC) has determined that the HCPCS codes to use when billing the Moore Balance Brace are :
- L1940 – ankle foot orthosis, molded to patient, plastic
- L2820 – addition to lower extremity orthoses, soft interface for molded plastic, below knee section
The 2012 maximum allowable fees for these codes are:
- L1940 $571.10
- L2820 $100.28
The Moore Balance Brace is commonly prescribed bilaterally to address risk factors contributory to increased risk of falling.
Frequently determined diagnoses related to increased risk for falling that might benefit from the stability afforded by the MBB include:
- Muscle weakness (728.87)
- Ataxia, muscular incoordination (781.3)
- Gait abnormality/ staggering, ataxic (781.2)
- Osteoarthritis, localized primary ankle & foot (715.17)
- Arthropathy, unspecified, ankle and foot (716.97)
- Pain in joint, ankle, foot (719.47)
- Instability of joint, ankle & foot (718.87)
- Dropfoot (736.79)
- Hemiplegia (438.20)
Arizona AFO, the manufacturer of the Moore Balance Brace believes that like it’s other gauntlet devices, the MBB should also be verified for HCPCS code L2330, with the comment, “used whether the closure is a lacer closure or a Velcro closure” and has scheduled an in-person appeal in Fargo, ND in April.
Suppliers are advised that until the PDAC reconsiders the verification determination that only codes L1940 and L2820 be used for billing purposes.
For additional information about the Moore Balance Brace or fall prevention please see the SafeStep forum (safestepforum.net), blog (safestepblog.net) or contact SafeStep at 866.712.STEP (7837) or email firstname.lastname@example.org.
Medicare recently announced that the design of an L1906, multi ligamentous ankle support must “include a rigid stirrup and foot plate which provides functional tracking of the ankle with hind-foot and mid-foot stability during ambulation” and that devices that meet the description are now required to have a PDAC verification letter. See the full descriptions below:
We have received updated HCPCS Coding Verification letters on both the Swede-O Arch Lok and Atom Hinged Ankle braces.
Notifications on other devices in this category will be forthcoming as they become available.
Until March 31, 2012, a PDAC verification letter has not been required for a device to qualify for Medicare reimbursement. It has simply been necessary that the device meet the description described below:
L1906 ANKLE FOOT ORTHOSIS, MULTILIGAMENTOUS ANKLE SUPPORT, PREFABRICATED, INCLUDES FITTING AND ADJUSTMENT
A multiligamentous ankle support provides control of the ankle joint between the medial and lateral malleoli while allowing for dorsiflexion and plantar flexion. This off-the-shelf ankle support includes a rigid stirrup and foot plate which provides functional tracking of the ankle with hind-foot and mid-foot stability during ambulation. This, in conjunction with wrap-around straps and the inherent gauntlet design, offers areas of multiligamentous support as described by the code. There are no additional HCPCS codes for this type of prefabricated ankle orthosis.
Additionally, Medicare said
Effective for claims with dates of service on or after April 1, 2012, the only products which may be billed to Medicare using code L1906 (ANKLE FOOT ORTHOSIS, MULTILIGAMENTUS ANKLE SUPPORT, PREFABRICATED, INCLUDES FITTING AND ADJUSTMENT) are those for which a written coding verification has been made by the Pricing, Data Analysis, and Coding (PDAC) contractor and that are listed in the Product Classification Matrix of the DME Coding System (DMECS). Products which have not received coding verification review from the PDAC must be billed with code A9270. Please refer to the advisory article titled Coding Guidelines for Ankle Foot Orthoses.
Products that are currently listed on DMECS with L1906 will be end dated effective March 31, 2012 and changed to A9270 until a coding verification review has been completed by the PDAC.
Thus, it is mandatory that manufacturers submit to PDAC devices for L1906 verification in order for them to qualify for reimbursement.
There are some multi ligamentous type devices that have been recommended to be billed using L1906 code such as the Ossur Exoform and the GameDay that do not have a foot plate. As such they would need to be billed as A9270. They might more appropriately meet the description of L1902. See description below:
L1902 ANKLE FOOT ORTHOSIS, ANKLE GAUNTLET, PREFABRICATED, INCLUDES FITTING AND ADJUSTMENT
The Donjoy Velocity (and Ossur Rebound) are recommended by the manufacturers to be billed using code L1971. This is based on the description below:
L1971 ANKLE FOOT ORTHOSIS, PLASTIC OR OTHER MATERIAL WITH ANKLE JOINT, PREFABRICATED, INCLUDES FITTING AND ADJUSTMENT
For a complete list of products that are currently listed on PDAC site with L1906 code see the link below:
In summary, the new ruling affects items billed using L1906 not L1971. Some items currently filed as L1906 will need to be reclassified as L1902. All items that meet new definition of L1906 will need a verification letter starting April 1, 2012.
Podiatrists can improve patients’ lives and help reduce the overall cost of healthcare by implementing a comprehensive fall prevention program. SafeStep offers ample opportunity and encourages podiatrists to learn more about how to start one and to not be frightened by alerts and postings that imply an assumption of great risk by utilizing custom AFOs as a part of treatment.
“Comparative Billing Reports” from Medicare demonstrate that on average, DPMs dispense 0.7 L1940 devices, per podiatrist, PER YEAR! There is not a problem of custom AFO over utilization but most definitely one of underutilization.
Medicare policy is clear that patients documented to have orthopedic risk factors for falls are covered for custom AFO’s including the Moore Balance Brace. Recent posts intended to discourage AFO utilization serve as reminders of the importance of following established treatment protocols and of Medicare documentation requirements.
The Medicare LCD states that to be covered, an item must “be reasonable and necessary for the diagnosis or treatment of illness or injury or to improve the functioning of a malformed body member”.
The Medicare Benefit Policy Manual states that appliances are covered when “used for the purpose of supporting a weak or deformed body member or restricting or eliminating motion in a diseased or injured part of the body.”
If biomechanical examination determines any of the following diagnoses to be present, clinical indications demonstrating medical necessity are met and that if dispensing custom AFO’s, podiatrists can be confident of satisfying Medicare guidelines:
Muscle weakness (728.87)
Ataxia, muscular incoordination (781.3)
Gait abnormality/ staggering, ataxic (781.2)
Osteoarthritis, localized primary ankle & foot (715.17)
Arthropathy, unspecified, ankle and foot (716.97)
Pain in joint, ankle, foot (719.47)
Instability of joint, ankle & foot (718.87)
SafeStep will continue to be a strong supporter of podiatrists’ role in fall prevention and embraces the opportunity to dispense custom AFO’s as a legitimate means of treatment.
Earlier this month, the Department of Health and Human Services released the initial core of health care quality measures for Medicaid –eligible adults. This is something I think we should all look at and understand when managing Medicaid information.
Some of the other information in this release includes measures for: prevention, management of chronic conditions and other measurements.
To read the entire release, find it on the document below:
There’s a reason Facebook is one of the key places to focus on for marketing your practice. With 100’s of millions of members, you can bet you will get more eyes on your practice from prospective and existing customers. dedicated server Combine those effects with an effective email marketing campaign and you have a recipe for marketing success.
Today, I want to give you a few ways to use Facebook to get more likes, responses and generate more leads to your practice.
Using Facebook For Podiatry Practice Marketing
- Use photos and videos – Most online visitors love things they can see and hear. This is perfect for showcasing your skills and benefits of your practice to potential customers. Look at adding your YouTube channel and other photos to your Facebook page. Add videos of your success stories, how to informational videos and even photos of your products. Don’t forget to link out to others in your industry for interesting, curated content.
- Tie in your email list – Depending on what email marketing provider you use, you can add a tab on your Facebook page to gather leads that opt-in to your email newsletter.
- Use a welcome page – Don’t just have visitors land on your wall, develop a landing page that shows up for those who haven’t yet liked your page. Combine a compelling offer on your welcome page that tells your visitors to like you and give them something in return.
There are other effective ways to use Facebook to market your practice, but these are some of the best ways to ensure your customers and prospects get the best experience when they visit your Facebook page.
In the catalog, you will find the best brands, the most styles and the greatest comfort shoes and inserts for those in need of specialized shoes for a healthier, more active and more comfortable lifestyle.
To view the catalog, simply access it at the following page:
This is a letter that was sent to http://www.podiatrym.com along with Josh’s response:
Having just read that 90%** of post-payment audits show fraud (mistakes do not occur when any provider bills for a service: Contact your local RAC auditor) and 93%** of pre-payment audits reveal the same, I was relieved to post the following message in my waiting room:
“We no longer participate, endorse, recommend or prescribe MediCare Diabetic Shoes.”
In my opinion, a physician who participates in ANY aspect of the CMS Diabetic Shoe Progam needs to re-evaluate the level of risk-taking. There exists an overwhelming probability that they may not only be repaying large amount of monies back to CMS, but they may be soon finding their reputations and their very licenses under attack. It is very, very clear that the CMS’s ultimate goal is to make every physician a criminal.
Response from Josh
Medicare’s revisions to the Therapeutic Shoe Program speak to a desire to improve quality of care and work very effectively to DPMs’ advantage. I think that the main reason why over 90% of suppliers failed post-payment audits for therapeutic shoe claims is that they did not completely understand Medicare documentation requirements nor how to efficiently comply. Fortunately compliance need not be onerous using a program developed by SafeStep called “WorryFree DME”. By streamlining documentation procurement and guaranteeing Medicare compliance, fitting diabetic shoes should be seen as very worthwhile.
An explanation of each of the six required pieces of documentation and how each might be easily obtained using the “WorryFree DME” program, should provide a comfort level that speaks to the foolishness of rejecting participation in the Medicare program. SafeStep offers free training webinars on Medicare compliance and the ease of using it’s WorryFree DME program. Click here to sign up: http://www.safestep.net/Members/WebinarInfo.asp
Fear of audits resulted last year in a 20% decrease in the the number of shoes paid for by Medicare while the number of people on Medicare increased by 10%. In 20 years, the number of people with Medicare and diabetes is expected to QUADRUPLE. In my experience, the reason why most podiatrists are not fitting nearly as many shoes as they have the potential to is failure to have good protocols in place and responsibilities assigned to capable, enthusiastic people in the practice. There should be someone to ensure that every patient who has diabetes is evaluated to determine if they qualify for shoes, is fit when appropriate and is rechecked on an annual basis. While such an approach requires some work and a change in the way most offices operate, I suggest that the $200 or more profit possible from fitting each pair of shoes should comfortably offset whatever additional cost is needed to ensure such a program’s success.
Given such programs as PQRS and the Therapeutic Shoe Program, CMS is making it very, very clear that it’s ultimate goal is not to make every physician a criminal but to promote a team approach to comprehensive, cost effective, preventative care.
Josh White, DPM, CPed
President / Founder, SafeStep