July 7, 2014
Excision or Curettage of Bone Cyst or Benign Tumor by Podiatrists
After reviewing scope of practice guidelines for podiatrists in Ohio and Kentucky and relevant medical literature, CGS has determined that CPT code 27635 (excision or curettage of bone cyst or benign tumor, tibia or fibula) is within the scope of practice for podiatrists if the procedure directly impacts on the foot and/or ankle. Effective for claims submitted on or after August 21, 2014, CGS will review claims for this service, submitted by podiatrists, for medical necessity. If not submitted with the claim, CGS will request documentation to support this service, which should indicate the direct impact the bone cyst or benign tumor is having on the foot and/or ankle. This documentation must be present in order for the procedure to meet medical necessity requirements.
Special Notes Regarding Signatures
Please note that all services ordered or rendered to Medicare beneficiaries must be signed. While orders for diagnostic tests do not have to be signed, either the order must have a signature or the intent to order the specific test must be clearly documented in the medical record, and that must be signed. One or the other must be signed.
Signatures may be handwritten or electronic. With few exceptions, stamped signatures are not acceptable, as described in the CMS Program Integrity Manual (Pub. 100-08), chapter 3, section 3.3.2.4. CMS MLN Matters article MM8219 describes another exception for stamped signatures. Under the added exception, CMS will permit the use of a rubber stamp for signature in accordance with the Rehabilitation Act of 1973 in the case of an author with a physical disability that can provide proof to a CMS contractor of his/her inability to sign their signature due to a disability. By affixing the rubber stamp, the provider is certifying that he/she has reviewed the document.
If the signature is handwritten, it must be legible or have a signature line with a typed and/or printed version of the name of the person signing. If the signature is electronic, the signature must include a phrase similar to "electronically signed by" or "reviewed by," etc., and may include the date and time of the signature.
Please note that only the person actually performing the service can sign the documentation. A partner or provider covering for another cannot sign the order, record or attestation statement.
Reference:
- For more information about amending medical records, refer to the CGS web article "Entries in Medical Records: Amendments, Corrections, and Delayed Entries"
- Refer to CMS MLN Matters article MM6698, "Signature Guidelines for Medical Review Purposes" for a comprehensive overview of signature requirements.
Updated: 12.22.23