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Routine Foot Care for Certain Medical Conditions
07.07.01r

Policy

When services can be administered in various settings, the Company reserves the right to reimburse only those services that are furnished in the most appropriate and cost-effective setting that is appropriate to the member’s medical needs and condition. This decision is based on the member’s current medical condition and any required monitoring or additional services that may coincide with the delivery of this service.

When a benefit exists, routine foot care is considered medically necessary and, therefore, covered once every 60 days when both of the following criteria are met:
  • The individual has a peripheral circulatory disorder or diminished sensation in the legs or feet as a result of one or more of the diagnoses listed below:
    • Amyotrophic lateral sclerosis (ALS)
    • Arteriosclerosis obliterans (ASO) (e.g., arteriosclerosis of the extremities, occlusive peripheral arteriosclerosis)
    • Arteritis of the feet
    • Buerger disease (thromboangiitis obliterans)
    • Chronic indurated cellulitis
    • Chronic thrombophlebitis*
    • Chronic venous insufficiency
    • Diabetes mellitus*
    • Intractable edema, secondary to a specific disease (e.g., congestive heart failure, kidney disease, hypothyroidism)
    • Lymphedema, secondary to a specific disease (e.g., Milroy disease, malignancy)
    • Peripheral neuropathies involving the feet:
      • Associated with malnutrition and vitamin deficiency*
        1. Malnutrition (general, pellagra)
        2. Alcoholism
        3. Malabsorption (celiac disease, tropical sprue)
        4. Pernicious anemia
      • Associated with carcinoma*
      • Associated with diabetes mellitus*
      • Associated with drugs and toxins*
      • Associated with multiple sclerosis*
      • Associated with uremia (chronic kidney disease)*
      • Associated with traumatic injury
      • Associated with leprosy or neurosyphilis
      • Associated with hereditary disorders
        1. Hereditary sensory radicular neuropathy
        2. Amyloid neuropathy
        3. Angiokeratoma corporis diffusum (Fabry disease)
    • Peripheral vascular disease
    • Raynaud disease
*NOTE: When the individual's condition is one of those designated by an asterisk (*), routine procedures are covered only if the individual is under the active care of a professional provider who documents the condition.
  • The individual has one of the following:
    • A Class A finding of a nontraumatic amputation of foot or integral skeletal portion thereof
    • Two of the following Class B findings:
      • Absent posterior tibial pulse
      • Absent dorsalis pedis pulse
      • Advanced trophic changes (at least three of the following are required):
        1. Hair growth (decrease or absence)
        2. Nail changes (thickening)
        3. Pigmentary changes (discoloration)
        4. Skin texture (thin, shiny)
        5. Skin color (rubor or redness)
    • One Class B finding (see above) and two of the following Class C findings:
      • Claudication
      • Temperature changes (e.g., cold feet)
      • Edema
      • Paresthesias (abnormal spontaneous sensations in the feet)
      • Burning
Whirlpool treatment performed prior to routine foot care, to soften the nails or skin, is considered part of the routine foot care services and, therefore, is not eligible for separate reimbursement.

REQUIRED DOCUMENTATION

The individual's medical record must reflect the medical necessity for the care provided. These medical records may include, but are not limited to: records from the professional provider's office, hospital, nursing home, home health agencies, therapies, and test reports.

The Company may conduct reviews and audits of services to our members, regardless of the participation status of the provider. All documentation is to be available to the Company upon request. Failure to produce the requested information may result in a denial for the service.

For routine foot care in the presence of qualifying covered systemic conditions, the medical record must contain a sufficiently detailed description of the feet to support that nonprofessional performance of the service is hazardous to the individual. Furthermore, the following physical and clinical findings, which are indicative of severe peripheral involvement, must be documented and maintained in the individual’s medical record. The professional provider rendering the routine foot care has identified, in addition to a primary condition, either (1) the Class A finding (Q7); (2) two of the Class B findings (Q8); or (3) one Class B and two Class C findings (Q9).

BILLING REQUIREMENTS

When nail trimming is performed as an individual service, report the appropriate individual service code. When routine foot care is performed as a comprehensive service, report the appropriate comprehensive Healthcare Common Procedure Coding System (HCPCS) code instead of the code for the individual services.

All codes for routine foot care services should be reported only once per visit regardless of the number of lesions or nails treated.

When reporting routine foot care services in the presence of qualifying covered systemic conditions, the applicable Q modifier (Q7, Q8, or Q9) identifying the class findings must be included on the claim.

When reporting one of the ICD-10-CM codes that fall under the "active care requirement", the date that the individual was last seen by the professional provider responsible for treating the underlying condition must be reported in line 19 of the CMS-1500 claim form or the electronic equivalent.

Guidelines

BENEFIT APPLICATION

Subject to the terms and conditions of the applicable benefit contract, when a benefit exists, routine foot care is covered under the medical benefits of the Company’s products when the medical necessity criteria listed in this medical policy are met. Individual member benefits must be verified as benefits for routine foot care may vary by product and group and may be excluded.

Description

Routine (i.e., palliative or cosmetic) foot care is typically performed by a professional provider (e.g., podiatrist or primary care provider) for the purposes of inspecting and treating an individual's feet for sequelae of systemic conditions including decreased circulation, skin and nail irregularities, alteration in nerve sensations, foot deformities, swelling, ulceration, or drainage.

Routine foot care includes the treatment of:
  • Corns, also known as a Misspelled Wordclavus: a thickened hard growth of skin
  • Calluses, also known as aMisspelled Word tyloma or tylomata: a thickening of skin of the horny layer due to locations of pressure or friction
  • PlMisspelled Wordantar keratosis, hyperkeratosis, and keratotic lesions: outer layers of skin that become overgrown and thick
  • Bunions (except capsuMisspelled Wordlar or bone surgery thereof): inflammation from long-term pressure and irritation at the joint area located at the base of the great toe
  • Nails (except surgery for ingrown nails)
Foot care that would otherwise be considered routine (e.g., cutting or removing corns/calluses, trimming, cutting, clipping, or debriding nails) is usually not routine when the individual has a systemic condition that results in severe circulatory embarrassment or areas of diminished sensation in the legs or feet. For these individuals, routine foot care procedures should be performed by a professional provider (e.g., podiatrist or primary care provider [PCP]) to minimize the risk for infection or circulatory compromise.

References

American Academy of Orthopaedic Surgeons (AAOS). Care of the Diabetic Foot. [AAOS Web site]. Last reviewed October 2023. Available at: https://orthoinfo.aaos.org/en/treatment/care-of-the-diabetic-foot. Accessed March 24, 2026.

American Diabetes Association (ADA). Microvascular Complications and Foot Care: Standards of medical care in diabetes – 2021. Diabetes Care. 201;44(Suppl. 1):S151-S167.

American Diabetes Association. Standards of medical care in diabetes—2022. Diabetes Care. 2022; 45(Suppl. 1):S46-S59.

Centers for Medicare & Medicaid Services (CMS). Medicare Benefit Policy Manual. Chapter 15: Covered Medical and Other Health Services. §290: Foot care. [CMS Web site]. 03/24/21. Available at: https://www.cms.gov/Regulations-and-Guidance/Guidance/Manuals/downloads/bp102c15.pdf. Accessed March 24, 2026.

Centers for Medicare & Medicaid Services (CMS). National Coverage Determination (NCD) 70.2.1: Services Provided for the Diagnosis and Treatment of Diabetic Sensory Neuropathy with Loss of Protective Sensation (aka Diabetic Peripheral Neuropathy). [CMS website]. 07/01/02. Available at:
https://www.cms.gov/medicare-coverage-database/details/ncd-details.aspx?NCDId=171&ncdver=1&bc=AAAAQAAAAAAA&. Accessed March 24, 2026.


Company Benefit Contracts.

Frykberg RG, Zgonis T, Armstrong DG, et al. Diabetic foot disorders: A clinical practice guideline. J Foot Ankle Surg. 2006;45(5 Suppl):S1-S66.

Harless LB, Satterfield VK, Dennis KJ. Role of the podiatrist. In: Bowker JH, Pfeiffer MA, eds. Levin and O'Neal's The Diabetic Foot. 6th ed. St. Louis, MO: Mosby, Inc; 2001: 682-699.

Novitas Solutions, Inc. A52996: Routine foot care (article). [Novitas Solutions Web site]. 10/01/2015. (Revised 10/01/2025). Available at: https://www.cms.gov/medicare-coverage-database/view/article.aspx?articleid=52996&ver=31&​ Accessed March 24, 2026.

Novitas Solutions, Inc. Local Coverage Determination (LCD). L35138: Routine foot care. [Novitas Solutions Web site]. 10/01/2015 (Revised 10/17/2019). Available at: https://www.cms.gov/medicare-coverage-database/details/lcd-details.aspx?LCDId=35138&ver=43&Date=06/11/2020&SearchType=Advanced&DocID=L35138&bc=KAAAAAgAAAAA&. Accessed March 24, 2026.​

Pinzur MS, Slovenkai MP, Trepman E, Shields NN. Diabetes Committee of American Orthopaedic Foot and Ankle Society. Guidelines for diabetic foot care: recommendations endorsed by the Diabetes Committee of the American Orthopaedic Foot and Ankle Society. Foot Ankle Int. 2005;26(1):113-119.

Rathur HM, Boulton AJ. The diabetic foot. Clin Dermatol. 2007;25(1):109-120. ​​​

Coding

CPT Procedure Code Number(s)
11719
ICD - 10 Procedure Code Number(s)
N/A
ICD - 10 Diagnosis Code Number(s)
See Attachments A, B, C, D, and E.
HCPCS Level II Code Number(s)
G0127 Trimming of dystrophic nails, any number

G0247 Routine foot care by a physician of a diabetic patient with diabetic sensory neuropathy resulting in a loss of protective sensation (lops) to include if present, at least the following: (1) local care of superficial wounds, (2) debridement of corns and calluses, and (3) trimming and debridement of nails

S0390 Routine foot care; removal and/or trimming of corns, calluses and/or nails and preventive maintenance in specific medical conditions (eg, diabetes), per visit
Revenue Code Number(s)
N/A

Modifiers

Q7 One Class A finding

Q8 Two Class B findings

Q9 One class B and 2 class C findings

Coding and Billing Requirements

Policy History

Revisions From 07.07.01r:​
​04/29/2026

​This policy has been reviewed and reissued to communicate the Company’s continuing position on routine foot care for certain medical conditions.​​
10/01/2025

This policy has been identified for the ICD-10 CM code update, effective 10/01/2025.


The following ICD-10 CM codes have been deleted from Attachment C of the Routine Foot Care for Certain Medical Conditions medical policy: 

G35  Multiple sclerosis


The following ICD-10 CM codes have been added to Attachment B as eligible to be reported for Routine Foot Care for Certain Medical Conditions:


E11.A Type 2 diabetes mellitus without complications in remission

The following ICD-10 CM codes have been added to Attachment C as eligible to be reported for Routine Foot Care for Certain Medical Conditions:

G35.A Relapsing-remitting multiple sclerosis
G35.B0 Primary progressive multiple sclerosis, unspecified
G35.B1 Active primary progressive multiple sclerosis
G35.B2 Non-active primary progressive multiple sclerosis
G35.C0 Secondary progressive multiple sclerosis, unspecified
G35.C1 Active secondary progressive multiple sclerosis
G35.C2 Non-active secondary progressive multiple sclerosis
G35.D Multiple sclerosis, unspecified



Revisions From 07.07.01q:​​
​04/16/2025
​This policy has been reissued in accordance with the Company's annual review process.
​03/06/2024
​​This policy has been reissued in accordance with the Company's annual review process.
​02/22/2023
​This policy has been reissued in accordance with the Company's annual review process.
02/09/2022

This policy has been reissued in accordance with the Company's annual review process.

​10/01/2021
​This policy has been identified for the ICD-10 CM code update effective 10/01/2021.​


The following ICD-10 CM code has been added to Attachment C as eligible to be reported for Routine Foot Care for Certain Medical Conditions:

E75.244: Niemann-Pick disease type A/B


Revisions From 07.07.01p:
07/28/2021The policy has been reviewed and reissued to communicate the Company's continuing position on Routine Foot Care for Certain Medical Conditions.​
​10/01/2020

​This policy has been identified for the ICD-10 CM ​code update effective 10/01/2020.

 

The following ICD-10 CM codes have been added to Attachment D as eligible to be reported for Routine Foot Care for Certain Medical Conditions:

N18.30: Chronic kidney disease, stage 3 unspecified

N18.31: Chronic kidney disease, stage 3a

N18.32: Chronic kidney disease, stage 3b


The following ICD-10 CM code has been termed from Attachment D of this policy:
N18.3: Chronic kidney disease, stage 3 (moderate)​​


Revisions From 07.07.01o:
08/26/2020The policy has been reviewed and reissued to communicate the Company's continuing position on Routine Foot Care for Certain Medical Conditions.
​10/01/2019

​This policy has been identified for ICD-10 code update effective 10/01/2019.
The following ICD-10 codes I70.238 and I70.248 have revised narratives.
The following ICD-10 codes have been added to the policy: I80.241, I80.242, I80.243, I80.249, I80.251, I80.252, I80.253 and I80.259.​

Revisions From 07.07.01n:
08/14/2019The policy has been reviewed and reissued to communicate the Company's continuing position on Routine Foot Care for Certain Medical Conditions
07/022018This version of the policy will become effective 07/02/2018.

The policy has been reviewed and issued to communicate the Company’s position on Routine Foot Care For Certain Medical Conditions.

The Medical Necessity requirements have been amended the medical necessity criteria as follows due to correction in LCD.

The following ICD-10 CM codes have been added to Attachment C in this policy:
E85.81 Light chain (AL) amyloidosis
E85.82 Wild-type transthyretin-related (ATTR) amyloidosis
G12.25 Progressive spinal muscle atrophy

Revisions From 07.07.01m:
11/17/2017This policy has undergone a routine review, and the Medical Necessity requirements have been re-ordered and updated to identify conditions for which the individual must be under the active care of a professional provider.

The following Modifiers have been added to the policy:
    Q7 One Class A finding
    Q8 Two Class B findings
    Q9 One class B and 2 class C findings

The following ICD-10 CM codes have been deleted from this policy:
    E10.37X1: Type 1 diabetes mellitus with diabetic macular edema, resolved following treatment, right eye

    E10.37X2: Type 1 diabetes mellitus with diabetic macular edema, resolved following treatment, left eye

    E10.37X3: Type 1 diabetes mellitus with diabetic macular edema, resolved following treatment, bilateral

    E10.37X9: Type 1 diabetes mellitus with diabetic macular edema, resolved following treatment, unspecified eye
Billing Requirements have been added.

Language added to Required Documentation section to clarify reporting requirements related to rationale for provision of care by professional provider.

Effective 10/05/2017 this policy has been updated to the new policy template format.
10/1/2025
10/1/2025
4/29/2026
07.07.01
Medical Policy Bulletin
Commercial
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Independence Blue Cross is a subsidiary of Independence Health Group, Inc. — independent licensees of the Blue Cross and Blue Shield Association, serving the health insurance needs of Philadelphia and southeastern Pennsylvania.