Pedorthists Should Consider Referencing AFO, not SCFO in Their Patient Notes
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Pedorthists Should Consider Referencing AFO, not SCFO in Their Patient Notes

Note:  Part of PFA's role is to pass along this information and make suggestions that may be helpful to our members.  However, each individual practitioner is solely responsible for proper documentation and billing practices.

As you know, the Centers for Medicare and Medicaid Services (CMS) have increased documentation requirements across all of its benefit programs – DMEPOS, physicians, hospitals, etc.Concurrent with this, audit activity by CERTs, RACs and other Medicare contracted auditors to ensure compliance with the more stringent documentation requirements has increased, and more and more claims are being rejected for inappropriate documentation of medical necessity.

PFA has identified a technical, or syntactical problem for those credentialed and/or licensed pedorthists who dispense Subtalar-Control Foot Orthosis known as SCFOs.

SCFOs, with specific anatomical boundaries as detailed in some of the credentialed and licensed pedorthist scopes of practice, are really Ankle-Foot Orthosis' (AFOs).  The term SCFO is completely unknown and unrecognized outside of pedorthics and O & P.  There are no HCPCS codes unique to SCFOs; referring and prescribing physicians indicate AFO in their patient charts and notes; billing companies recognize the term AFO but not SCFO; and, Medicare and other insurance carriers also recognize AFO but not SCFO.

This presents a dilemma for the credentialed and/or licensed pedorthist who utilizes the full scope of practice and dispenses SCFOs (or, more appropriately, anatomically limited AFOs based on the scope of practice) when it comes to maintaining consistency between their patient notes, and the patient's physician notes, orders, billing claims, medical policies, etc.  During the course of an audit, PFA believes that credentialed and/or licensed pedorthists may be at risk to have their claims for SCFOs denied if their patient notes include the unfamiliar term SCFO and are thus inconsistent with all other documentation indicating the familiar term AFO.  As such, PFA suggests that credentialed and/or licensed pedorthists may want to consider appropriately utilizing the term Ankle-Foot Orthosis, or AFOs, documenting the anatomical region that the device has been fit and dispensed for, in their patient notes as well.  Essentially, you should maintain consistency between what is prescribed, what is dispensed and what is documented.

PFA will work with those affected credentialing and licensing bodies as well concerning the language in the pedorthic scopes of practice specific to SCFOs, requesting that the term be replaced with AFO, along with detailed anatomical boundaries.

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