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To clarify, I assume you are asking this question about two services performed on the same DOS and on the same anatomical site. That is both the Column I (a lower fee) code is billed at the same time that the Column II (a higher fee) code is performed. If that is correct, then... Medicare stipulates that you must document all procedures that were performed. I think what you are asking here is whether you choose to bill for all those services that you performed may be thought of as a separate and distinct issue. In my opinion, Medicare doctrine stipulates that you must document what you performed and that in order to bill for something you must have it documented. Those statements don't require you however to bill for everything you performed, in particular for services which are non covered. Then there is also the looming issue here of purposely not billing everything which was performed in order to avoid being paid the lower fee for the Column I code by not billiing for it. If you don't document that you performed a particular service, then there could be a looming professional liabilty issue on whether or not you followed SOC. I don't have a definitive opinion on this and I am interested in hearing what others might have to say to continue this debate...

Let me add this comment, Jenny. Everything Paul wrote is spot on. There are some narrow circumstances where Medicare does not cover as it would be statutorily non covered, but the secondary does cover foot orthotics. Case in point is Federal BCBS. You bill the L3000RTGY and L3000LTGY. GY means, the service is statutorily non covered. Then, Federal BCBS would process if the diagnoses are those that match their medical policy. In my area, we use Carefirst BCBS policy for Federal claims and this is what this link says when submitting claims "Medicare claims billed using a 'GY' modifier can be submitted directly to CareFirst without prior submission to Medicare. These claims are not impacted by the 30 day requirement and do not require the inclusion of a Medicare EOB" https://provider.carefirst.com/providers/claims/medicare-secondary.page The following are examples of conditions for which orthotic foot inserts are considered medically necessary: • tenosynovitis • neuroma, ganglioneuroma • chronic arthritic pain • diabetic foot disease / ulcers (see Therapeutic Shoes for Individuals with Diabetes, Policy 1.02.015) • bunions • tendonitis, achilles tendonitis • plantar fasciitis with or without heel spur • tarsal tunnel. The following are examples of conditions for which orthotic foot inserts are considered not medically necessary: • calluses • corns • fallen arches • flat feet The following are examples of non-covered items which are not considered to be orthotic foot inserts: • arch supports, over-the-counter • external lifts, such as elevated heels which are part of a shoe • footwear • items required for special interest activities or employment not considered to be routine daily living activities (e.g., running shoes, braces, etc.) • items that are primarily intended to assist in sports activities • items usually stocked by neighborhood pharmacies • disposable items • vasco heel cups