05/16/2017
Billing MCR/MCAID for 11721-FQHC
In part of my workweek, I am employed by an FQHC known as LISH, overseen by Hudson River HC. I mostly see a mix of indigent patients, whose insurance will frequently include medicaid and/or medicare, and have billed according to the latter's rules. Specifically, when debriding nails, only a procedure code is used, unless there is a separate issue requiring further evaluation and management. Recently I received a memo stating that I had to add E&M codes to my 11721's and other similar CPT's as procedures "were not covered in the FQHC world". This seems to contradict the way I was informed that Medicare should be billed. Does anyone have any experience with billing for FQHC's, and is this request reasonable and, more importantly, legal? Anyone's help would be greatly appreciated.
After reviewing the Routine Foot Care LCD Policy and the sections of the Medicare Claims Processing Manual specifically for RHC/FQHCs and Podiatry, findings show that there is no stipulation that would suggest that a podiatrist rendering services in that setting would need to bill an E&M code instead of a routine foot care procedure code.
Please refer to the two links from CMS:
Overview of billing requirements for FQHCs (podiatry is mentioned in section 110).