This is an informational article on the plan to implement a service specific audit on procedure code 11721. Any billing of this procedure code should meet the guidelines set forth in the Consortium policy AC-03-003 (LCD AC-03-003: DEBRIDEMENT OF TOENAILS).

Data Analysis shows the AR Consortium with a standard deviation in Carrier data greater than 3.0 in allowed services per beneficiary for procedure code 11721. In addition, the data indicates providers are billing:

• Debridement codes (11720, 11721) when actually performing routine foot care,
• Billing Evaluation and Management code with Modifier 25 on the same date of service as debridement when no separate identifiable service was documented,
• No documentation for the extent of debridement, and
• Billing modifier 59 and another procedure code on the same date of service as debridement, with no documentation to support a distinct procedural service.