47 Percent of Diabetic Shoe Claims Are Flagged as Improper: What Podiatry Practices Need to Fix

Why Are Nearly Half of Diabetic Shoe Claims Being Denied?

As of the 2024 Medicare reporting period, the improper payment rate for diabetic therapeutic shoes reached 47.1 percent, with a projected improper payment amount of $35.7 million, according to CMS Comprehensive Error Rate Testing (CERT) data highlighted in the July 23, 2026 MLN Connects newsletter. The primary cause is insufficient documentation, which accounted for 85.5 percent of all improper payments. For podiatry practices that prescribe and certify therapeutic shoes, this means the claims are being submitted correctly in most cases but the supporting documentation is not meeting CMS requirements.

Documentation drives nearly all errors.
85.5 percent of improper payments were caused by insufficient documentation, not coding mistakes or beneficiary eligibility issues.

OIG launched a dedicated audit.
The HHS Office of Inspector General announced Project OAS-26-09-070 on May 29, 2026, specifically targeting Medicare payments to suppliers for therapeutic shoes, covering more than $143 million in payments from 2024 and 2025.

The fix is procedural, not clinical.
The documentation requirements are specific and checklistable. Practices that build these steps into their workflow can reduce their improper payment exposure substantially.

What CMS Flagged on July 23

The CMS MLN Connects newsletter published on July 23, 2026, directed providers to review the updated Therapeutic Footwear compliance tip, which reports the 2024 CERT improper payment data for diabetic shoes billed under HCPCS codes A5500 through A5513. The data shows that 47.1 percent of therapeutic shoe claims reviewed by CERT were classified as improper, projecting to $35.7 million in improper payments across the Medicare Fee-for-Service program.

This is not a new problem, but the scale is striking. Nearly one in every two claims for diabetic therapeutic shoes fails the documentation review. The Noridian DME MAC, which processes these claims for a large portion of the country, reported a similar 48 percent potential improper payment rate in its own Targeted Probe and Educate (TPE) review results. The consistency across CERT and TPE data confirms that this is a systemic documentation issue, not an isolated billing error.

Separately, the HHS OIG announced a dedicated audit on May 29, 2026 (Project OAS-26-09-070), specifically examining Medicare payments to suppliers for therapeutic shoes for enrollees with diabetes. The audit covers payments exceeding $143 million across calendar years 2024 and 2025. The combination of CMS compliance alerts and an active OIG audit signals that therapeutic shoe billing is now a high-priority enforcement area.

Does This Affect My Podiatry Practice?

If your practice prescribes, certifies, or fits diabetic therapeutic shoes under the Medicare Part B benefit, you are directly in scope. The therapeutic shoe benefit under Section 1861(s)(12) of the Social Security Act requires a prescribing physician, a certifying physician managing the patient’s diabetes, and a qualified fitter. Podiatrists frequently serve in all three roles or in the prescribing and fitting roles while the patient’s primary care physician or endocrinologist serves as the certifying physician.

The documentation burden falls on both the certifying physician and the supplier. But because podiatrists are often the provider initiating the therapeutic shoe order and managing the patient’s foot condition, incomplete documentation in the podiatrist’s chart is where many of these claims fail. One question we hear constantly from podiatry practice managers is whether their documentation would survive a CERT review. In most cases, when we look at how the billing companies we vet handle podiatry coding and documentation, the practices with clean therapeutic shoe claims are the ones that use a dedicated checklist for every shoe order, not the ones relying on the provider to remember each requirement from memory.

What Does Medicare Require for Therapeutic Shoe Claims?

The documentation requirements for therapeutic shoes are specific and must all be present in the medical record before the claim is submitted. Missing any single element can trigger an improper payment finding. Here is what CMS requires under LCD L33369 and the associated policy articles.

The certifying physician (the provider managing the patient’s diabetes) must document an in-person visit within the 12 months preceding the shoe order that addresses the patient’s diabetes management. The visit note must describe the patient’s diabetic condition, document the qualifying foot condition (such as peripheral neuropathy, foot deformity, previous amputation, poor circulation, or history of foot ulceration), and include a statement that the patient needs therapeutic shoes as part of a comprehensive diabetes plan of care.

The certification statement itself must be a separate, signed document that includes the patient’s name, the qualifying foot condition, and the physician’s attestation that the patient needs therapeutic shoes. If the in-person visit was conducted by a practitioner other than the certifying physician, the certifying physician must initial, date, and indicate agreement with the visit documentation before signing the certification. This specific requirement, where the certifying physician initials a visit note from another provider, is one of the most frequently missed steps identified in CERT and TPE reviews.

Requirement	What Must Be in the Record	Most Common Error
In-person diabetes visit	Visit note within 12 months addressing diabetes management	Visit note does not mention diabetes or foot condition
Qualifying foot condition	Documentation of neuropathy, deformity, amputation, ulcer history, or circulation issues	Condition listed on claim but not described in the chart
Certification statement	Signed statement with patient name, foot condition, and attestation	Statement missing or unsigned
Practitioner agreement	Certifying physician initials and dates visit note from another practitioner	Certifying physician signs without initialing the other provider’s note
Standard Written Order	Order specifying item, quantity, and patient identification	SWO missing quantity to be dispensed
Supplier documentation	Proof of fitting, delivery, and ABN if applicable	Fitting documentation not retained or not linked to claim

How Should Podiatry Practices Fix Their Therapeutic Shoe Billing?

The 47.1 percent error rate is a documentation problem, which means it is fixable with process changes. Here is what to implement now.

1. Build a therapeutic shoe documentation checklist. Create a single-page checklist that maps every required element. Attach it to every shoe order. Do not submit the claim until every box is checked.
2. Verify the certifying physician’s documentation before fitting. Before the shoe fitting appointment, confirm that the certifying physician has completed and signed the certification statement, that the qualifying foot condition is documented in the chart, and that the in-person diabetes visit occurred within 12 months.
3. Require the certifying physician to initial other providers’ notes. If the diabetes management visit was performed by a nurse practitioner, PA, or other practitioner, the certifying physician must initial, date, and indicate agreement with that note. Build this into the workflow as a mandatory step before the certification is signed.
4. Include the quantity on every Standard Written Order. The Noridian TPE review specifically flagged missing quantities on SWOs. Every order must specify the item type (depth shoe or custom-molded shoe), the number of pairs, and the number of inserts.
5. Retain supplier fitting documentation in the patient’s record. The fitting notes, delivery confirmation, and any Advance Beneficiary Notice (ABN) must be accessible for audit. If your practice handles fitting in-house, these records must be in the chart. If an outside supplier handles fitting, confirm they retain and can produce the documentation.
6. Audit a sample of recent therapeutic shoe claims. Pull 10 to 20 claims from the last six months and run each one against the checklist. If more than 10 percent fail, your process has a gap that needs to be closed before more claims go out. Across the billing companies we vet for podiatry practices, the ones that maintain a low improper payment rate on therapeutic shoes are the ones that run this self-audit quarterly.

Common Mistakes That Trigger Improper Payments

Providers often come to us after a claim has been denied or flagged in a TPE review. The same documentation mistakes appear in almost every case.

• Confusing the prescribing physician with the certifying physician. The certifying physician must be the provider managing the patient’s diabetes, not necessarily the podiatrist. If the podiatrist is not managing the diabetes, a separate certification from the managing physician is required. Submitting a claim without this distinction is the fastest way to trigger a denial.
• Documenting the foot condition on the claim but not in the chart. A diagnosis code on the claim is not a substitute for clinical documentation in the medical record. CERT reviewers pull the chart, not the claim. If the qualifying foot condition is not described in the visit note, the claim is improper regardless of what codes are on the form.
• Billing therapeutic shoes as DME. Therapeutic shoes for diabetic patients are not classified as DME or orthotics under Medicare. They are a separate Part B coverage category under Section 1861(s)(12). Billing them through the wrong pathway creates processing errors and can result in denials that are difficult to appeal.
• Not linking the shoe order to a comprehensive diabetes care plan. Medicare requires that the therapeutic shoes be part of a comprehensive plan of care for the patient’s diabetes. The certification must reference this plan. A standalone shoe order without a documented care plan context fails the coverage requirement.

Frequently Asked Questions

Next Steps

• Start by auditing a sample of your recent therapeutic shoe claims against the documentation checklist. If gaps appear, implement the checklist workflow before submitting additional claims. Review the podiatry billing and coding cheat sheet for a broader overview of documentation standards across all podiatric services.
• If your practice needs a billing partner with podiatry-specific experience handling therapeutic shoe documentation, CERT compliance, and OIG audit readiness, Podiatry Bill Co connects you with vetted billing companies that specialize in this exact workflow.