The last two installments in this forum dealt with the first two steps of required documentation for reimbursement for custom foot orthotics. To summarize those steps were proper clinical documentation of medical necessity to meet the merits of the third party payer’s policy and the required elements of the fabrication/prescription process.
The final step in the proper documenting of prescription custom foot orthotics is the dispensing visit. Believe it or not there are required essential elements in the acutal fitting and dispensing of custom foot orthotics, which if not properly documented can result in claim denial upon audit.
Proper documentation of the fitting, adjustment and dispensing of foot orthotics like any DME item, requires a complete written statements in the chart by the provider and an acknowledgement by the patient that those statements were fulfilled by the provider.
Let’s look at each one of these individually.
How does the device fit? Is there full contact with the patient’s arch on wt. bearing? Does the patient’s pathology appear to be corrected on weight bearing with the device? One common example is a patient with an excessive rearfoot frontal plane deformity? Does the device completely or mostly resolve the patient’s pathology and to what extent? A proper photograph of the patient taken from the rear with and without the foot orthotics can be self-explanatory to any auditor. If the correction is not complete a rationale for why total correction is unwarranted or contraindicated should be stipulated in the chart. What about the patient’s gait? Has their gait significantly improved with the orthotics? If so how?
Adjustments: Many patients require some tinkering with their custom foot orthotics in order to fit more comfortably. If that was required, what exactly was done? There are far too many adjustment techniques and examples on which to elaborate here. But suffice it is to say if you did something to the orthotic to adjust it, whether prior to billing for it or afterwards, please document it.
Once the device is fitted and any required adjustments are made, it is imperative to include the same information in the chart as in the laboratory’s invoice, bill of lading or shipping information about the device. That is they must be consistent with each other. The rationale is that the auditors will look to see if there is any discrepancy between what was ordered and received as this could potentially affect the HCPCS code used to bill the device (next article).
The patient should also be provided with oral instructions (to be reiterated with written instructions -see below) on how to gradually break in the device. The patient should be given information on the correct type of shoes to wear with the device.
The last and most overlooked step is to obtain a Written Proof of Delivery (WPOD) from the patient.
While most providers are aware of Medicare’s requirements for WPOD under the Therapeutic Shoe Policy for Patients with Diabetes, many do not realize that this proof of delivery is required for all third payers of DME and this includes foot orthotics.
The WPOD should contain the following:
The name of the patient.
Description of the device (This could be the manufacturer’s name and model name/number and SKU/invoice number of the device).
It should contain patient instructions on use, application, shoe to shoe transfer and cautionary tales on what the patient should do and not do and when to call the office for further instructions. Most important it should reiterate your dispensing instructions regarding gradual break in of use of the device and references to any warranty information (whether indirect to the mfg. or your own policy).
Lastly the patient should sign and date when they received the device and where the device was dispensed (most likely your office).
The first three installments of this article on custom foot orthotic billing covered documenting medical necessity, the fabrication process, and this installment the fitting/adjustment/dispensing visit.
The last installment in this series will include proper billing for custom foot orthotics.
