The Centers for Medicare and Medicaid Services (CMS) has announced waivers and loosened some provider restrictions since the public health emergency was declared. There have been new announcements every day.
A concern among providers who dispense surgical dressings is the need to document, on a monthly basis, clinical information which demonstrates the reasonable and necessary requirements regarding the type and quantity of surgical dressings provided. This may prove difficult during this public health emergency but may be handled via telemedicine in some cases. Some common questions I have received are:
If a debridement was performed or a patient is recovering from surgery, can providers continue care and/or approve additional wound care supplies without seeing the wound in-person?
Yes. There are two ways around that right now.
The first way is to perform the monthly update using telemedicine. There is no requirement that this evaluation must be performed via a face-to-face visit. On March 17, CMS announced that CPT 99201-99215 can be submitted when providing these services remotely throughout the duration of the public health emergency. If all of the requirements in that announcement are met, the physician must provide the clinical information that demonstrates the necessity which can be accomplished using video/pictures.
The second way is completing the standard monthly eval “unless there is documentation which justifies why an evaluation could not be done within this timeframe”. If a patient needs surgical dressings during the public health emergency but this evaluation is not possible, given this guidance, it can be excluded if there is documentation explaining why. The doctor could document:
“Monthly eval was not performed due to the Public Health Emergency Declaration in response to the COVID-19 crisis. The risks and benefits of performing this eval were weighed, and in this case, under current CDC guidelines, the potential risks of having a face-to-face encounter with this patient outweighed the potential benefits. Therefore, a monthly eval of the wound was not performed. I feel comfortable ordering additional supplies in the absence of evaluating their wound given the circumstances."
The corresponding policy article passage reads:
Clinical information, which demonstrates that the reasonable and necessary requirements in the policy regarding the type and quantity of surgical dressings provided, must be present in the beneficiary's medical records. This information must be updated by the treating practitioner (or their designee) on a monthly basis. This evaluation of the beneficiary's wound(s) is required unless there is documentation in the medical record which justifies why an evaluation could not be done within this timeframe and what other monitoring methods were used to evaluate the beneficiary's need for ongoing use of dressings.
Are you aware of any changes to policies allowing physicians to diagnose a wound over the phone or using photos in order to approve shipment of supplies without performing debridement or surgery?
No. There have been a lot of waivers and guideline changes, but that policy has not changed. Physicians still need to perform the debridement or surgery to prescribe wound care supplies.
At the time of this writing, nothing has been announced that changes the coverage requirement indicating surgical dressings are only covered for a wound that was caused by or treated with a surgical procedure and for a wound that was debrided. The surgical procedure or debridement requirement has not changed.
DISCLAIMER: The information provided here is intended to educate health care providers regarding compliance for ICD, CPT, and HCPCS coding. The information provided does not guarantee reimbursement and is accurate to the best of our knowledge at the time of this publication. Coding guidelines can change and we encourage you to stay up to date. The existence of a code does not guarantee payment.
About the Author
Dr. Jeffrey D. Lehrman, DPM, FASPS, MAPWCA, CPCDr. 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.