Podiatry Billing Guide
Provider Qualifications
A doctor of podiatric medicine is a physician, but only with respect to those functions which he/she is legally authorized to perform in the State in which he/she performs them. The professional services furnished by a doctor of podiatric medicine within the scope of his/her applicable State license (except services which are specifically excluded) are physician's services payable on a reasonable charge basis under Part B. Where permissible by state law, these services include ordering laboratory tests that are reasonably related to the legal scope of podiatric practice, that are reasonable and necessary for the diagnosis or treatment of a patient's condition and are not in connection with excluded services, such as treatment of flat foot and routine foot care.
A doctor of podiatric medicine may hold any of the following professional degrees: Pod. D. or D. P. (Doctor of Podiatry), D.S.C. (Doctor of Surgical Chiropody), D.P.M. (Doctor of Podiatric Medicine), D.S.P. (Doctor of Surgical Podiatry), Graduate in Podiatry, Master Chiropodist, Graduate Chiropodist, or in some instances another podiatry degree. Within a particular State, all individuals holding any of these degrees are licensed to perform the same functions; however, there are variations from State to State as to the authorized scope of podiatric practice.
For purposes of the Medicare Program, a doctor of podiatric medicine is considered a physician for any of the following purposes:
- Making the required physician certification and recertification of the medical necessity for services;
- Having a patient in a home health agency under his/her care, and establishing and periodically reviewing a home health plan of treatment; or
- Serving as a member of a UR committee, but only if at least two of the physicians on the UR committee are doctors of medicine or osteopathy. The performance of these functions must be consistent with the scope of the professional services provided by a doctor of podiatric medicine as authorized by applicable State Law.
A doctor of podiatric medicine is not a physician for the purpose of performing any of the physician activities required to qualify an institution or organization as a SNF.
Effective for dates of service on or after 12/1/2023, a registered nurse that holds foot care certification such as CFCN® or CFCS or other similar certifications or independent training by supervising professionals may perform covered foot care services when all the following requirements are met:
- Services are performed under direct supervision of a physician or other practitioner
- All requirements of the “incident to” provision are met per the CMS Medicare Benefit Policy Manual
- Proof of accredited Foot Care Nurse certification must be available for National Government Services on request
- All other coverage provisions outlined in this Billing and Coding Article are met
Providers should be aware that this may not be allowed, based on their state scope of practice laws.
Revised 9/16/2024