WASHINGTON—The Endocrine Society has penned a joint letter to CGS and the durable medical equipment Medicare administrative contractors (DME MACs) requesting an urgent increase in beneficiary access to medically necessary therapeutic shoes for people with diabetes.
In the letter the Endocrine Society states there has been a significant and steady decrease in access to therapeutic shoes for people with diabetes which raises concerns for patients to develop peripheral neuropathy, which increases the risk for diabetic foot ulceration, infection and amputation.
"To address the concerns outlined above, the undersigned organizations ask the DME MACs to remove the following sentence from 'Therapeutic Shoes for Persons with Diabetes - Policy Article' (A52501): 'Obtain, initial, date (prior to signing the certification statement), and indicate agreement with information from the medical records of an in-person visit with a podiatrist, other M.D or D.O., physician assistant, nurse practitioner or clinical nurse specialist that is within 6 months prior to delivery of the shoes/inserts, and that documents one of more of criteria a – f.,'" the letter said.
The Society continued that the change would align with a recent policy the Centers for Medicare & Medicaid Services (CMS) passed in its 2025 Physician Fee Schedule (PFS) final rule, where CMS recognized the administrative burden associated with certifying a patient’s plan of care (POC) for therapy services. The final rule included a requirement that a physician or non-physician practitioner sign the initial POC with a dated signature or verbal order within 30 days from the first day of treatment, in order for the physical therapist, occupational therapist or speech language pathologist to be paid for the services.
"Under CMS’s final policy, rather than requiring the physician/notice of privacy practices (NPP) signature on the POC, CMS and its contractors are now able to treat a signed and dated physician/NPP therapy order or referral as equivalent to a signature on the POC for the purposes of the initial certification, if the order or referral indicates the type of therapy needed and the written order or referral is on file in the medical record," The Society said. "Like the original policy that was modified in the calendar year 2025 PFS Final Rule (requiring a signature on a POC before a therapist can be paid for a service), the coverage requirement for therapeutic shoes—requiring a managing physician to sign a podiatrist’s or other physician’s medical record notes for certification to be valid—is excessively burdensome and impedes access to care.
"Our request to eliminate the managing physician’s signature requirement, like the final 2025 PFS policy, would eliminate unnecessary burden and remove barriers to care and, in the process, support the delivery of evidence-based foot care for patients with diabetes."
The Society then called for a meeting with DME MAC directors to discuss the problem further and to find an appropriate solution.
For full access to the letter, click here.