Re: Diabetes Debridement Coding

Dr. Kass responded to the answer that was made by Dr. David Freedman with respect to the question that was posed to “The Coding Helpline” on Tuesday, September 22, 2026.

The bottom line is that per CMS rules and regulations, one cannot be reimbursedfor the debridement of a toenail on the same toe that an HPK is pared, if the HPK islocated on or distal to the distal interphalangeal joint (ie. DIPJ). Even though the 59 orthe XS modifier is appended to either CPT code 11720 or CPT code 11721, which will allow for payment of the nail debridement CPT code, the medical record documentation would have to accurately and specifically show that the nail was NOT debrided on the same toe that had an HPK pared that was distal to or over the DIPJ.

I totally agree with Dr. Freedman. This is very important in the event of an audit to support what was billed and what was performed. Dr. Kass’ big issue is the following: “If work is being done that is legitimate, why should it not be paid?” I agree with Dr. Kass to a degree. When you sign a contract with Medicare, you agree to follow the rules. Unfortunately, this is one of the rules.

Let’s take this just one step further. CPT code 11720 is defined as the following: Debridement of nail(s) by any method(s); 1 to 5 CPT code 11721 is defined as the following: Debridement of nail(s) by any method(s); 6 or more. How often do you only debride the nail on a toe and trim an HPK on the same toe that is over or distal to the DIPJ on a patient as the only service performed? Rarely, if ever.

Based upon the definitions of CPT codes 11720 and 11721, with very few exceptions, you are going to get reimbursed the same amount even if you don’t bill for the debridement of the nail on the same toe that an HPK was pared that was over the DIPJ or distal to the DIPJ.

Let’s take this a step further: What about the great toe? The great toe does not have a DIPJ or a PIPJ. It only has anIPJ. So…..? If the nail on the great toe is debrided and an HPK is pared anywhere on the great toe, both the nail debridement and the paring of the callus can be billed with either the 59 modifier or the XS modifier appended to either CPT code 11720 or CPT code 11721.

Let’s take this a third step further: For the “at risk,” routine foot care patient, can a dystrophic toenail (HCPCS Level II code G0127) or a non-dystrophic toenail (CPT code 11719) be trimmed, and a corn/callus be trimmed on the same toe if the callus is located over or distal to the DIPJ? When the NCCI edits are accessed, CPT codes 11055, 11056, and 11057 are NOT bundled with either HCPCS Level II code G0127 or CPT code 11719. Therefore, CPT code 11719 or HCPCS Level II code G0127 and CPT code 11055 should be reported together for paring of a callus performed on skin distal to and including the skin overlying the distal interphalangeal joint on the same toe where the toenail is trimmed. Modifier 59 should be applied to either HCPCS Level II code G0127 or CPT code 11719.

This is my opinion.

—Michael G. Warshaw, DPM, CPC, CSFAC, COCS, CPODCS, CMSCS