One more comment posted this morning seems to have the definitive answer.
_________________
Jim,
I am a trained CMS facility accreditation inspector and pedorthic /
therapeutic shoe instructor. Opinion does not matter with CMS, only rules. I
sent you a link to the OIG’s recommended Statement of Certifying Physician
Statement that clearly states MD or DO. Fraud is a hot topic in CMS circles
right now and people are going to learn how it works the hard way. CMS
has/will pull reimbursement on EVERY pair of shoes that people do not follow
the rules on, if you get caught. A CMS agent routinely follows up on around
10% of all FA inspection within months of initial inspection. Fraudulent
billers (whether they mean to be or not) will get caught. None of us want to
burn off a referral source, but rules are rules. PLEASE don’t take my
opinion on it. See below…
Department of Health and Human Services OFFICE OF INSPECTOR GENERAL
MEDICARE PAYMENTS FOR THERAPEUTIC SHOES
“According to HCFA’s documentation guidelines, a doctor of medicine or a
doctor of osteopathy who is treating the beneficiary’s systemic diabetic
condition under a comprehensive plan of care must certify the need for
therapeutic footwear. This physician must also certify that the beneficiary
suffers from one or more of the six qualifying conditions cited above. (A
certification form recommended by the DMERCs is presented in Appendix A.)
A podiatrist or other physician must order or prescribe the necessary
footwear. The footwear must be fitted and furnished by a podiatrist or other
qualified individual, such as a pedorthist, orthotist, or prosthetist. The
certifying physician may not supply the footwear unless he or she is the
only qualified individual operating in the geographical area serving the
beneficiary’s address.”
http://oig.hhs.gov/oei/reports/oei-03-97-00300.pdf
Regards and stay legal brother…
—
Jim Thelen, LPO
Trinidad Medical Consultants
jimth@trinidadmedical.com
214-340-6200
