How Would a Medicare Reimbursement Code for Annual Preventive Diabetic Foot Exams Impact Patient Care?

Diabetes mellitus is a chronic but manageable disease. In the United States, 27.2 million people aged 65 years or older (48.8%) have prediabetes and 38.4 million people (11.6% of the U.S. population) have been diagnosed with diabetes.¹ As podiatrists are well aware, peripheral neuropathy, peripheral arterial disease (PAD) and foot ulcers are among its most debilitating complications. Diabetic foot ulcers (DFUs) precede 85% of non-traumatic lower limb amputations,² yet many are preventable with early detection and mitigation of risks. Despite the proven benefits of preventive foot exams,³ Medicare does not currently provide a dedicated reimbursement code for an annual comprehensive diabetic foot evaluation. Failure to perform a diabetes-focused foot examination can lead to diagnostic and therapeutic gaps that could subsequently result in costly hospitalizations and amputations.

Medicare recognizes the benefits of preventive screenings in general and covers 26 preventive screenings, and a diabetes prevention program.⁴ There are codes for diabetes screening,⁵ diabetes self-management training,⁶ but there is no code for an annual preventive diabetic foot exam. I believe that the Centers for Medicare and Medicaid Services (CMS) should establish a specific Healthcare Common Procedure Coding System (HCPCS) or Current Procedural Terminology^® (CPT) code to reimburse clinicians for performing an annual preventive diabetic foot exam.

The Need for Annual Preventive Diabetic Foot Exams

Approximately 19-24% of people with diabetes will develop a foot ulcer in their lifetime, and that equates to a maximum of 6.5 million (24% of 27.2M Medicare aged adults with diabetes) people with foot ulcers of Medicare age in the United States.⁷ The most recent statistics reveal that the mean one year cost of treating a single DFU is $44,000⁸ whereas preventive care is far less expensive. The reported 5-year mortality rates have remained as high as 83% after a diabetes related lower extremity amputation,⁹ emphasizing the need for early intervention. Podiatrists are deeply aware of this need, and are well-positioned to provide the necessary care to work towards early detection and amputation prevention. 

Current Gaps in Medicare Coverage

While Medicare covers foot care services for qualifying, high-risk patients, there is no dedicated reimbursement for a preventive, structured foot exam in patients with diabetes who do or may not have pedal symptoms or may not meet class findings. Many podiatrists and primary care providers (PCPs) perform these exams but use evaluation and management (E/M) codes, which I contend do not adequately reflect the specialized nature of the service.

Proposed Solution: A Dedicated Medicare Reimbursement Code

I recommend that CMS establish a new CPT code specifically for an annual comprehensive diabetic foot evaluation. In my experience, the contents of such an exam should include the following:
•    Monofilament testing for sensory neuropathy as well as sharp /dull, vibration deep tendon reflexes and temperature differentials
•    Vascular assessment including pedal pulses, capillary return, and skin temperature. If the results of the vascular exam reveal concern for circulatory issues, an ankle-brachial index (ABI), or photoplethysmography (PPG) may be indicated either from the provider or via referral. 
•    Dermatologic inspection for ulcers, bone, soft tissue (hyperkeratosis) or nail deformities, along with evaluation for skin moisture, fissures, and interdigital inspection.
•    Musculoskeletal exam of biomechanics / gait, ranges of motion and shoe gear
•    Patient and caregiver education on proper foot care and prevention.
•    There is indeed supporting evidence for what podiatrists already know. 
•    American Diabetes Association (ADA) Guidelines recommend annual foot exams for all patients with diabetes and more frequent exams for high-risk patients.¹⁰
•    Studies show structured foot care programs reduce amputations by 45-85%.^11,12
•    Private insurers and VA systems already reimburse for preventive diabetic foot care, setting a precedent for Medicare.^13-15

Some may argue that:

"E/M codes are sufficient." I would counter that E/M codes do not incentivize structured foot exams, potentially leading to inconsistent care.

"It will increase Medicare costs." Instead, I feel preventive care reduces long-term costs by avoiding ulcers, infections, hospitalizations, and amputations.

In Conclusion

Given the high prevalence of diabetes-related foot complications and the proven benefits of early detection, I feel Medicare must adopt a dedicated reimbursement code for annual preventive diabetic foot exams. This change could improve patient outcomes by identifying and mitigating risks for foot ulcer development at an early stage. Such a code could reduce long-term costs by preventing hospitalizations and amputations and will align better Medicare with ADA and private insurer guidelines. 

References
1. Healogics. Diabetes wound healing. Accessed September 23, 2025. [https://www.healogics.com/wound-care-patient-information/diabetes-wound-healing]
2. Boulton AJM, Armstrong DG, Albert SF, et al. Comprehensive foot examination and risk assessment. Diabetes Care. 2008;31(8):1679-1685. doi:10.2337/dc08-9021
3. Medicare.gov. Preventive screening services. Accessed September 23, 2025. [https://www.medicare.gov/coverage/preventive-screening-services]
4. Medicare.gov. Diabetes screenings. Accessed September 23, 2025. [https://www.medicare.gov/coverage/diabetes-screenings]
5. Medicare.gov. Diabetes self-management training. Accessed September 23, 2025. [https://www.medicare.gov/coverage/diabetes-self-management-training]
6. Hingorani A, LaMuraglia GM, Henke P, et al. The management of diabetic foot: A clinical practice guideline by the Society for Vascular Surgery. J Vasc Surg. 2016;63(2 Suppl):3S-21S. doi:10.1016/j.jvs.2015.10.003. PMID: 36548709. [https://pubmed.ncbi.nlm.nih.gov/36548709/]
7. Diabetic Foot Online. Cost of illness studies in chronic ulcers: a systematic review. Published April 11, 2017. Accessed September 23, 2025. [https://diabeticfootonline.com/2017/04/11/cost-of-illness-studies-in-chronic-ulcers-a-systematic-review/]
8. Conte MS, Bradbury AW, Kolh P, et al. Global vascular guidelines on the management of chronic limb-threatening ischemia. J Vasc Surg. 2019;69(6 Suppl):3S-125S.e40. doi:10.1016/j.jvs.2019.02.016. [https://www.jvascsurg.org/article/S0741-5214(21)01761-4/fulltext]
9. American Diabetes Association. Comprehensive foot examination and risk assessment. Diabetes Care. 2008;31(8):1679-1685. doi:10.2337/dc08-9021. [https://diabetesjournals.org/care/article/31/8/1679/28543/Comprehensive-Foot-Examination-and-Risk]
10. American Podiatric Medical Association. Fact sheet: studies prove podiatrists prevent complications, provide savings. Accessed September 23, 2025. [https://www.apma.org/advocacy/advocacy-policy/issue-and-policy-briefs/federal-advocacy/fact-sheet-studies-prove-podiatrists-prevent-complications-provide-savings/V]
11. Wound Care Weekly. Global preventive foot care and a decrease in amputations. Published June 21, 2025. Accessed September 23, 2025. [https://woundcareweekly.com/2025/06/21/global-preventive-foot-care-and-a-decrease-in-amputations/]
12. US Department of Veterans Affairs. VHA Directive 1173.21: Diabetic limb salvage. Published September 20, 2021. Accessed September 23, 2025. [https://www.va.gov/vhapublications/ViewPublication.asp?pub\_ID=9852]
13. Kaiser Family Foundation. Preventive services covered by private health plans. Accessed September 23, 2025. [https://www.kff.org/womens-health-policy/preventive-services-covered-by-private-health-plans/]
14. Anthem. Clinical utilization management guidelines. Accessed September 23, 2025. [https://www.anthem.com/medpolicies/abcbs/active/gl\_pw\_e002057.html]