Home Health & Hospice

Medicare Doesn't Routinely Cover Routine Foot Care

Homecare Insider, October 26, 2009

OASIS-C has questions encouraging agencies to implement evidence-based practices for diabetic foot care. This brings up a question: Will Medicare cover diabetic foot care performed by a nurse, assuming that all other Medicare coverage criteria are met?

Many agencies have a policy mandating a registered nurse to perform foot care on diabetic patients or those with peripheral vascular disease. Because this patient is at risk for problems, these agencies view foot care as a procedure requiring the skills of a nurse, thereby qualifying the patient for Medicare coverage. However, that is not a correct assumption.

When deciding how to care for diabetic patients’ feet, look at Medicare coverage guidelines. Medicare doesn’t cover routine foot care, which is defined as:
• cutting or removal of corns or calluses
• trimming, cutting, clipping, or debriding of nails
• hygienic and preventive maintenance care such as cleaning and soaking the feet and application of skin creams to maintain skin tone of either ambulatory or bedfast patients, and
• any other service performed in the absence of localized illness, injury, or symptoms involving the foot.

From this description, it’s evident that foot care, even if it’s for a diabetic patient, doesn’t always require the skills of a nurse. However, there are exceptions to this policy. A medical condition exists that places the patient at increased risk of infection and/or injury if a nonprofessional provides these services. Medicare would then recognize foot care as requiring the skills of a nurse, thereby qualifying the patient for coverage.

Here are the exceptions to the definition of routine foot care (from CMS Publication 100-2, Chapter 15, §290.B.2):
• The patient has a systemic condition such as metabolic, neurologic, or peripheral vascular disease that may result in severe circulatory embarrassment or areas of diminished sensation in the individual’s legs or feet.
• There is clear evidence of significant circulatory changes.
• The clinical record must identify the systemic condition (diagnosis) and the size and exact location of each lesion treated.
• The frequency of visits to perform foot care must be reasonable.

Beacon Health’s next audio conference on November 19 will analyze the good and bad of new OASIS-C data elements, along with evidence-based practices for foot care and depression.