No. The reference for this is in the National Correct Coding Initiative (NCCI).1,2

The Guidance

Chapter IV, Section G.2 of the NCCI Policy Manual states:

Casting/splinting/strapping CPT Codes shall not be reported for application of a dressing after a therapeutic procedure.”

The Merriam-Webster dictionary3 defines “therapeutic” as, “of or relating to the treatment of illness.” Debriding an ulcer is certainly related to the treatment of the ulcer. Therefore, ulcer debridement is considered therapeutic. Application of an Unna boot is certainly considered a “strapping.” The word “strapping” is even used in the CPT® code4 representing the application of an Unna boot.

CPT 29580- Strapping: Unna boot

Therefore, both debriding an ulcer and applying an Unna boot to the same limb on which the ulcer is present fall under the reporting restriction illustrated by Chapter IV, Section G.2 of the 2022 Policy Manual.

NCCI PTP Edits

In addition to the Policy Manual, the NCCI publishes procedure-to-procedure (PTP) edits for certain CPT code combinations. These edits are usually based upon the standards of medical/surgical practice1. When one service is considered to be an integral component of another service, the CPT codes that represent the two services are paired by a NCCI PTP edit. In general, when a pair of services is provided at the same encounter whose CPT codes are paired by a NCCI PTP edit with a modifier of “1”, both CPT codes should not be reported unless it is clinically appropriate to use an NCCI PTP-associated modifier. In this case, the column 2 CPT code of the pair is considered to be a component of the column 1 CPT code of the pair. CPT 29580 is paired with all of the ulcer debridement code in column 1 and CPT 29580 in column 2, indicating that Unna boot application is considered to be a component of the ulcer debridement and not separately reportable when performed at the same time.

The Exception

If an ulcer debridement is performed on one lower extremity and an Unna boot is applied on the contralateral extremity, both services may be submitted with an appropriate modifier indicating that these two services were performed at different sites.

References

1 National Correct Coding Initiative Procedure-To-Procedure Edits

2 National Correct Coding Initiative Policy Manual For Medicare Services 

3 Merriam Webster Dictionary 

4 CPT 2022 Professional Edition Current Procedural Terminology (CPT) is copyright 1966, 1970, 1973, 1977, 1981, 1983-2021 by the American Medical Association. All rights reserved. CPT is a registered trademark of the American Medical Association (AMA).

Dr. Jeffrey D. Lehrman, DPM, FASPS, MAPWCA, CPC
Dr. Jeffrey D. Lehrman, DPM, FASPS, MAPWCA, CPC

Dr. Lehrman is in private practice in Fort Collins, CO and operates Lehrman Consulting, LLC. He is a Diplomate of the American Board of Foot and Ankle Surgery, Fellow of the American Society of Podiatric Surgeons, and is recognized as a “Master” by the American Professional Wound Care Association. He is a Fellow of the American Academy of Podiatric Practice Management and an Expert Panelist on Codingline. In his role as a Consultant to the APMA Health Policy and Practice Department, Dr. Lehrman serves as an advisor to the APMA Coding Committee and the APMA MACRA Task Force. Dr. Lehrman sits on the board of directors of both the American Professional Wound Care Association and the American Society of Podiatric Surgeons. He is also on the editorial advisory board of the journal WOUNDS.