Series: Medicare Part B Payments for Podiatry and Ancillary Services

Announced on 04/11/2022 | Last Modified on 12/04/2025 | Series Number: W-00-24-35818

Status

Completed

Agency

Centers for Medicare and Medicaid Services

OBJECTIVE

Medicare Part B covers podiatry services for medically necessary treatment of foot injuries, diseases, or other medical conditions affecting the foot, ankle, or lower leg. Part B generally does not cover routine foot-care services such as the cutting or removal of corns and calluses or trimming, cutting, clipping, or debridement (i.e., reduction of both nail thickness and length) of toenails. Part B may cover these services, however, if they are performed (1) as a necessary and integral part of otherwise covered services, (2) for the treatment of warts on the foot, (3) in the presence of a systemic condition or conditions, or (4) for the treatment of infected toenails. Medicare generally does not cover evaluation and management (E&M) services when they are provided on the same day as another podiatry service (e.g., nail debridement performed as a covered service). However, an E&M service may be covered if it is a significant separately identifiable service. In addition, podiatrists may order, refer, or prescribe medically necessary ancillary services such as x-rays, laboratory tests, physical therapy, durable medical equipment, or prescription drugs. Prior OIG work identified inappropriate payments for podiatry and ancillary services. We will review Part B payments to determine whether podiatry and ancillary services were medically necessary and supported in accordance with Medicare requirements.

There are 2 projects in this series.

COMPLETED PROJECTS IN THIS SERIES (2)

Podiatrists' Claims for Routine Foot Care Services Did Not Comply with Medicare Requirements

Project A-09-22-03011 • Completed on December 4, 2025

Podiatrists' Claims for Evaluation and Management Services Did Not Comply With Medicare Requirements

Project A-09-22-03012 • Completed on December 3, 2025

TIMELINE

April 11, 2022

Series Number W-00-24-35818 Assigned
April 11, 2022

Projects Announced
Podiatrists' Claims for Routine Foot Care Services Did Not Comply with Medicare Requirements - A-09-22-03011
Podiatrists' Claims for Evaluation and Management Services Did Not Comply With Medicare Requirements - A-09-22-03012
December 3, 2025

Project Complete - A-09-22-03012
Podiatrists' Claims for Evaluation and Management Services Did Not Comply With Medicare Requirements has been marked as complete. This audit resulted in 1 recommendation.
December 4, 2025

Project Complete - A-09-22-03011
Podiatrists' Claims for Routine Foot Care Services Did Not Comply with Medicare Requirements has been marked as complete. This audit resulted in 1 recommendation.
December 4, 2025

Series Complete
Medicare Part B Payments for Podiatry and Ancillary Services has been marked as complete.

2 REPORT PUBLISHED

Podiatrists’ Claims for Routine Foot Care Services Did Not Comply With Medicare Requirements (A-09-22-03011)

Of the 100 sampled claims, 49 podiatrists’ claims for RFC services related to a systemic condition did not comply with Medicare requirements.
During our audit period, CMS’s oversight may not have been sufficient to prevent improper payments.
On the basis of our sample results, we estimated that of the $18.2 million paid by Medicare for our audit period, approximately $4.4 million did not comply with Medicare requirements.

26-A-09-019.01 to CMS - Open Unimplemented

Update expected on 06/03/2026

We recommend that the Centers for Medicare & Medicaid Services work with the MACs to analyze RFC care claims related to systemic conditions billed by podiatrists—specifically claims billed with E/M services—to determine whether additional oversight (e.g., guidance, education, medical reviews, and/or provider internal audits) is necessary to prevent improper payments, which amounted to an estimated $4,425,822 for our audit period.

View in Recommendation Tracker

Podiatrists’ Claims for Evaluation and Management Services Did Not Comply With Medicare Requirements (A-09-22-03012)

Of the 100 sampled claims, 44 podiatrists’ claims for E/M services did not comply with Medicare requirements.
During our audit period, CMS’s oversight may not have been sufficient to prevent improper payments.
On the basis of our sample results, we estimated that, of the $222.5 million paid by Medicare for our audit period, approximately $39.6 million did not comply with Medicare requirements.

26-A-09-018.01 to CMS - Open Unimplemented

Update expected on 06/02/2026

We recommend that the Centers for Medicare & Medicaid Services work with MACs to determine whether additional oversight (e.g., guidance, education, medical reviews, and/or provider internal audits) is necessary to prevent improper payments associated with podiatrists' billing of E/M services with modifier 25, which amounted to an estimated $39,583,052 for our audit period.

View in Recommendation Tracker

Work Plan Type

Office of Audit Services

HHS Agencies

Centers for Medicare and Medicaid Services

Issue Areas

Financial Stewardship

Target Groups

Financial Groups

Medicare B