Debridement of Mycotic Nails

This LCD supplements but does not replace, modify or supersede existing Medicare applicable National Coverage Determinations (NCDs) or payment policy rules and regulations for mycotic nail debridement services. Federal statute and subsequent Medicare regulations regarding provision and payment for medical services are lengthy. They are not repeated in this LCD. Neither Medicare payment policy rules nor this LCD replace, modify or supersede applicable state statutes regarding medical practice or other health practice professions acts, definitions and/or scopes of practice. All providers who report services for Medicare payment must fully understand and follow all existing laws, regulations and rules for Medicare payment for mycotic nail debridement services and must properly submit only valid claims for them. Please review and understand them and apply the medical necessity provisions in the policy within the context of the manual rules. Relevant CMS manual instructions and policies may be found in the following Internet-Only Manuals (IOMs) published on the CMS Web site:

IOM Citations:

• CMS IOM Publication 100-02, Medicare Benefit Policy Manual, Chapter 15, Section 290 Foot Care
• CMS IOM Publication 100-08, Medicare Program Integrity Manual, Chapter 13, Section 13.5.4 Reasonable and Necessary Provision in an LCD

Social Security Act (Title XVIII) Standard References:

• Title XVIII of the Social Security Act, Section 1862(a)(1)(A) states that no Medicare payment shall be made for items or services which are not reasonable and necessary for the diagnosis or treatment of illness or injury.
• Title XVIII of the Social Security Act, Section 1862(a)(7). This section excludes routine physical examinations.
• Title XVIII of the Social Security Act, Section 1833(e) states that no payment shall be made to any provider for any claim that lacks the necessary information to process the claim.
• Title XVIII of the Social Security Act, Section 1862(a)(13)(C) addresses routine foot care.

Notice: It is not appropriate to bill Medicare for services that are not covered (as described by this entire LCD) as if they are covered. When billing for non-covered services, use the appropriate modifier.

Compliance with the provisions in this policy may be monitored and addressed through post payment data analysis and subsequent medical review audits.

History/Background and/or General Information

As with other Medicare covered services, Mycotic Nail Debridement must be reasonable and necessary for the treatment of an illness or injury or to improve the functioning of a malformed body member; refer to CMS IOM Publication 100-08, Program Integrity Manual, Chapter 13 for more information. Medicare payment generally may be made for mycotic nail debridement in the two following circumstances:

1. As "routine foot care" under Medicare's national "Exceptions to Routine Foot Care Exclusions" provision when there is clinical evidence of mycosis of the toenail and the services and patient conditions meet national requirements for that exception.
   
   
2. When, whether or not the services and patient conditions meet national requirements for routine foot care, there is clinical evidence of mycosis of the toenail, and the patient has marked limitation of ambulation due solely to discomfort caused by the nails, (patients who are non-ambulatory for other reasons must have severe pain or impairment of some aspect of ADL) or has secondary soft tissue infection resulting from the thickening and dystrophy of the infected nail plate. The treatment of symptomatic mycotic nails in the absence of a qualifying covered systemic condition will not be covered after the acute symptoms caused by mycosis have abated. In the absence of a qualifying systemic condition, debridement of six or more nails in a single encounter is not payable without medical review of records associated with the service.

Onychomycosis may present as one or more nail findings, including hypertrophy/thickening, lysis, discoloration, brittleness or loosening of the nail plate. Fungal disease of the toenails is usually a relatively benign condition and may produce little or no symptoms beyond white opacities on the nails. Confirmation of mycotic nail infections by laboratory tests such as fungal cultures and/or stains is not necessary for Medicare coverage of debridement when clinical findings are strongly supportive of the diagnosis and treatment is not contraindicated. For coverage of mycotic nail debridement, mycologic confirmation by culture, potassium hydroxide examination, or dermatophyte testing is expected to differentiate fungal disease from other nail pathology in certain circumstances including but not limited to the following conditions: previous unsatisfactory treatment results (recurrent nail disease, unsuccessful treatment with FDA approved antifungal medications, long term - beyond 12 debridements per 24 months, etc.) and for patients whose debridement is prescribed absent of concomitant pharmacologic therapy.

Definitive treatment of mycotic nails involves the appropriate use of effective antifungal pharmacologic agents with or without periodic debridement of dystrophic nail plates to lessen the fungal load. Medicare will cover debridement of mycotic nails as an adjunct to pharmacologic treatment with a prescription antifungal agent indicated per its Food and Drug Administration (FDA) label for the treatment of fungal nail infections.

Debridement of nails, whether by electric grinder or manual method, is a temporary reduction in the length and thickness (short of avulsion) of an abnormal nail plate. This is usually performed without anesthesia. The debridement code should not be used if the only part of the nail removed is the distal nail border or other portion of nail not attached to the nailbed. Medicare expects debridement services reported for Medicare payment to include removal of maximal nail material possible (in consideration of the clinical condition of the nail and the patient's degree of comfort during the procedure) required for control of symptoms or infection.

It is performed most commonly without anesthesia to accomplish any or all of the following objectives:

• Relief of pain
• Treatment of infection (bacterial, fungal, and viral)
• Temporary removal of an anatomic deformity such as onychauxis (thickened nail), or certain types of onychocryptosis (ingrown nail)
• Exposure of subungual conditions for the purpose of treatment as well as diagnosis (biopsy, culture, etc.)
• As a prophylactic measure to prevent further problems, such as a subungual ulceration in an insensate patient with onychauxis

Debridement of asymptomatic mycotic nails is considered to be routine foot care and not a covered service unless submitted with documentation of the complicating factor or condition required for Medicare reimbursement. 

Covered Indications

Whether by manual method or by electrical grinder, debridement is a modality used as part of the definitive antifungal treatment of onychomycosis.

Payment may be made for the debridement of a mycotic nail (whether by manual method or by electrical grinder) when definitive antifungal treatment options have been reviewed and discussed with the patient at the initial visit and the requirements outlined in the CMS IOM Publication 100-02, Medicare Benefit Policy Manual, Chapter 15, Section 290 Foot Care are met.

For patients with a systemic condition and clinical evidence of mycosis of the toenail, but who do not meet the above criteria, refer to Local Coverage Determination (LCD) L35138, Routine Foot Care.

Medicare does not routinely cover fungus cultures, KOH preparations, or dermatophyte testing performed on toenail clippings in the doctor's office. Identification of cultures of fungi, potassium hydroxide examination, or dermatophyte testing of the toenail clippings is medically necessary only:

• When it is required to differentiate fungal disease from psoriatic nails or other nail pathology.
• When a definitive treatment for a prolonged period of time is being planned involving the use of a prescription medication which could pose health issues.

Debridement of nails is considered reasonable and necessary when performed by physicians, doctors of osteopathy, podiatrists and non-physician practitioners (NPPs) when performed within their state scope of practice or when performed under the direction of a qualified provider.

Limitations

Whirlpool treatment prior to the debridement of mycotic nails to soften the nails or the skin is not eligible for separate reimbursement.

Debridement codes should not be used to report the simple trimming, cutting, or clipping of the distal nail plate.

This LCD imposes frequency limitations. For frequency limitations please refer to the Utilization Guidelines section below.

Notice: Services performed for any given diagnosis must meet all of the indications and limitations stated in this policy, the general requirements for medical necessity as stated in CMS payment policy manuals, any and all existing CMS national coverage determinations, and all Medicare payment rules. Refer to Billing and Coding: Debridement of Mycotic Nails, A56640, for applicable CPT codes and diagnosis codes.

The redetermination process may be utilized for consideration of services performed outside of the reasonable and necessary requirements in this LCD.

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Refer to the Local Coverage Article: Billing and Coding: Debridement of Mycotic Nails, A56640, for all coding information.

Documentation Requirements

1. All documentation must be maintained in the patient's medical record and made available to the contractor upon request.
2. Every page of the record must be legible and include appropriate patient identification information (e.g., complete name, dates of service[s]). The documentation must include the legible signature of the physician or non-physician practitioner responsible for and providing the care to the patient.
3. For each service encounter, the medical record should contain the number of nails debrided and a description of each nail, which requires debridement. This should include, but is not limited to, the size (including thickness) and color of each affected nail. In addition, the local pathology caused by each affected nail resulting in the need for debridement must be documented. When reporting debridement of nail(s) by any method(s); 6 or more, complete documentation must be provided for at least 6 nails. (In situations where several nails are identical in characteristics, it may be appropriate to combine those nails into the description.)
4. The medical record must demonstrate the necessity of debridement of each debrided nail considering the patient's usual activities. Clinical rationale for treatment of mycotic nails with less than definitive care (i.e., debridement without pharmacologic intervention) must be explained in the record. For coverage of mycotic nail debridement by reason of the presence of specified conditions (i.e., in the absence of a qualifying covered systemic condition), the record should contain a description of the specified condition beyond mention that the particular condition is present (e.g., painful nails, limited ambulation, infection). The medical record must clearly document which nails were treated at every visit.
5. Routine identification of cultures of fungi, potassium hydroxide examination, or dermatophyte testing in the toenail is medically indicated when necessary to differentiate fungal disease from other nail pathology, or when definitive treatment for prolonged oral or topical antifungal therapy has been planned. If fungal testing is performed and billed, documentation of the testing, results, and the need for the prolonged oral or topical antifungal therapy must be in the patient record and available to Medicare upon request.
6. Services for debridement of more than five nails in a single day may be subject to special review. Documentation to support the medical necessity of such services must be in the patient's record and available to Medicare upon request.
7. Documentation of mycotic nail debridement services to residents of nursing homes must include a current nursing facility order (dated and signed with date of signature) for mycotic nail debridement services issued by the patient’s supervising physician. Such orders must meet the following requirements:
   
   • The order must be dated and must have been issued by the supervising physician prior to mycotic nail debridement services being rendered.
   • Telephone or verbal orders not written personally by the supervising physician must be authenticated by the dated physician’s signature within a reasonable period of time following issuance of the order.
   • The order must be consistent with the attending physician’s overall plan of care.
   • The order must be for medically necessary services to address a specific patient complaint of physical finding.
   • Routinely issued or “standing” facility orders for mycotic nail debridement services that do not meet the above requirements are insufficient.
8. Documentation of mycotic nail debridement services to residents of nursing homes performed at the request of the patient or patient’s family/conservator should indicate if the request was from the patient or the patient’s family/conservator. When the request is from someone other than the patient, the documentation should identify the requesting person's relationship to the patient.

Utilization Guidelines

In accordance with CMS Ruling 95-1 (V), utilization of these services should be consistent with locally acceptable standards of practice.

• Medicare will cover debridement of nail(s) by any method(s); 1 to 5 and/or debridement of nail(s) by any method(s); 6 or more no more often than every 60 days.
• Medicare will cover no more than six (6) debridement sessions per patient per 12 months absent medical review of patient records demonstrating medical necessity.

Notice: This LCD imposes utilization guideline limitations. Despite Medicare’s allowing up to these maximums, each patient’s condition and response to treatment must medically warrant the number of services reported for payment. Medicare requires the medical necessity for each service reported to be clearly demonstrated in the patient’s medical record. Medicare expects that patients will not routinely require the maximum allowable number of services.

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Other Contractor's Policies

Other Contractor Local Coverage Determinations

"Routine Foot Care/Mycotic Nail Debridement," Trailblazer LCD, (00400) L12481, (00900) L23770.

"Treatment of Ulcers and Symptomatic Hyperkeratoses," Noridian Administrative Services, LLC LCD, (CO) L23770.

"Routine Foot Care," Noridian Administrative Services, LLC, (CO) L23756.

"Routine Foot Care," Arkansas BlueCross BlueShield (Pinnacle) LCD, (NM, OK) L11701 and L11826.

Original JH source; LCD L32634, Mycotic Nail Debridement

Contractor Medical Directors

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