Following sustained advocacy and multiple rounds of direct communication with CMS and the DME MACs, APMA has secured critical clarification regarding coverage criteria for therapeutic shoes for persons with diabetes. We have confirmed that co-signed notes are not required when specific documentation standards are met.
For Medicare coverage of therapeutic shoes for persons with diabetes, there is no need for the certifying physician to initial and date any of the podiatrist’s documentation if the certifying physician:
Had an in-person visit with the beneficiary during which diabetes management was addressed within six months prior to delivery of the shoes
Personally documents in the medical record of an in-person visit that the patient has diabetes and has one of the six conditions required for coverage of therapeutic shoes (and this occurs within six months prior to delivery of the shoes/inserts and prior to or on the same day as signing the certification statement)
Documents that they are treating the beneficiary under a comprehensive plan of care for diabetes
Documents that the patient needs diabetic shoes
Signs the certification statement on or after the date of the in-person visit and within three months prior to delivery of the shoes/inserts
As confirmed in the DME MAC Policy article “Therapeutic Shoes for Persons with Diabetes” (A52501), if each of the five steps listed above are performed, there is no need for the certifying physician to initial and date any of the podiatrist’s documentation.
This clarification represents a meaningful step toward reducing unnecessary administrative burdens that have frustrated providers and delayed patient care. APMA will continue working closely with CMS to ensure consistent interpretation of these requirements and to promote clear, practical education for providers, DME MACs, and other stakeholders.
At the same time, APMA remains committed to securing a permanent legislative solution. We are actively collaborating with champions in Congress to reintroduce legislation that will streamline the therapeutic shoe program and eliminate avoidable barriers that stand between patients with diabetes and medically necessary care.