OASIS-Central

As you review the OASIS-C data set questions encouraging agencies to implement EBP for diabetic foot care, you may find yourself asking 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 that a registered nurse 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
• 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 for a diabetic patient, doesn’t always require the skills of a nurse. However, there are exceptions to this policy. If a medical condition places the patient at increased risk of infection and/or injury when 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.

Therefore, with the diabetic foot care process measure (in M2250 and M2400) can be applied to show the best practice of assessing all diabetic patient’s feet, but not all diabetic foot care is a qualifying covered service.

This is an excerpt from the book, OASIS-C Process Measures: A Program for Best Practices Implementation, by April Perry, RN, APN, MEd, Laurie Salmons, RN, BSN, and Bobi Rose, RN, BSN, CWCN, CCCN. Learn more about the book here.