Foot Baths are ‘Afoot’
Foot Baths: Background
One of the biggest emerging schemes within healthcare prescription fraud is drugs involving foot baths. The Centers for Medicare and Medicaid Services (CMS) in collaboration with the Investigations Medicare Drug Integrity Contractor (I-MEDIC) has been made aware of questionable prescribing and dispensing patterns of several drugs that are being used in foot baths or ‘soaks’. It’s a recent trend very similar to the telemarketing scheme of topical pain creams and we strongly suggest health plans to actively data mine to stop the bleeding.
How does the Scheme Work?
Telemarketers initiate this scheme by luring patients in via cold-calling or ‘Robo-Calls’. Once the telemarketers obtain the necessary patient information they need, they work with independent ‘mom & pop’ pharmacies to bill a combination of three (3) therapeutic classes of drugs, typically Corticosteroids, Antibiotics, and Antifungals
(see NDC list of ingredients used in Foot Baths on Page 2) in high quantities.
i.e.: a claim for Clindamycin with a metric quantity unit of 1,800.
The beneficiaries are then instructed to dilute these unnecessary drugs they receive in water and mix the drugs in a foot bath to soak their feet. Given that the drugs are mixed and diluted in water, investigators and analyst should look for drugs with dosage forms in Capsules, Solutions, Powders, or Creams.
National Drug Code (NDC) List
| Foot Bath Ingredient |
NDC |
Foot Bath Ingredient |
NDC |
| Budesonide |
00093-6816-73 |
Itraconazole |
65162-0087-74 |
| Calcipotriene |
68462-0501-66 |
Ketoconazole |
51672-1298-02
00168-0099-30 |
| Ciclopirox Olamine |
45802-0400-49 |
Levofloxacin |
55150-0156-20
17478-0107-20 |
| Ciprofloxacin HCL |
61314-0656-10
69315-0308-02
61314-0656-25 |
Lidocaine and Tetracaine |
71800-0631-15 |
| Clindamycin Phosphate (Topical) |
00168-0201-30
00168-0202-60
45802-0562-01
51672-4081-04
21922-0002-01 |
Meropenem |
00409-1391-21 |
| Clobetasol Propionate |
51672-1259-03
60432-0133-25 |
Mupirocin |
68462-0180-22
51672-1312-00
00093-1010-42 |
| Diflorasone Diacetate |
71800-0009-60
51672-1295-03 |
Nystatin (Topical) |
00574-2008-15 |
| Doxycycline Hyclate |
00115-1327-13 |
Oxiconazole Nitrate |
51672-1359-03
00168-0358-60 |
| Econazole Nitrate |
52565-0022-30
51672-1303-02
70512-0029-30 |
Tobramycin |
65162-0914-46
00093-4085-63
67457-0473-22
39822-0412-06
17478-0340-38 |
| Erythromycin (Acne Aid) |
70512-0035-60 |
Triamcinolone Acetonide |
71800-0156-31 |
| Gentamicin Sulfate |
60758-0188-05
00713-0683-31 |
Vancomycin HCL |
68180-0167-13
68001-0338-62
68001-0339-64
00121-0890-20 |
| Hydrocortisone Butyrate |
51672-4074-06
68682-0270-45 |
Voriconazole |
47781-0466-71
68462-0573-30 |
What is the Medical Efficacy of Foot Baths?
Short answer: there is none. There is no clinical research supporting the efficacy of drugs involved in foot baths or this route administration method (mixing the drugs and soaking your feet).
Foot baths claim to treat medical diagnoses such as diabetic ulcers, bone infections, ingrown toenails, cellulitis, fungal infections, bacterial infections, and open wounds around the foot/ankle area. Soaking open foot wounds in water with powerful antibiotics is not standard of care and may cause further complications, or a potential patient harm issue.
One of the drugs that are often mentioned in foot baths is Vancomycin which is used to treat serious bacterial infections such as Methicillin-resistant Staphylococcus aureus (MRSA). In an article published by the Mayo Clinic, “most MRSA infections occur in people who’ve been in hospitals or other health care settings, such as nursing homes and dialysis centers.” This is a very common infection and anyone who is ill may develop this in their lifetime. The patient harm issue with using these powerful antibiotics when there is no infection is developing a resistance to that antibiotic. This ultimately means that if a patient developed MRSA and needed Vancomycin, that Vancomycin would not be effective due to the resistance.
Why should health plans monitor Foot Baths?
The challenges payers and health plans are faced with are that these inappropriate medications can be very costly and provide low value. Moreover, your health plan beneficiaries are possibly being targeted and potentially harmed by receiving these unnecessary drugs. Without any edits in place, these drugs are likely covered by insurance health plans at the point of sale. Continuous monitoring, detection, and prevention of these claims is a step to alleviate the risks of inappropriately billing.
What should your health plan consider as outlier utilization for foot baths?
- Pharmacy claims for Corticosteroids, Antifungals, and Antibiotics are billed in high quantities without correlating medical claims data
- Non-existent patient-physician relationship
- Excessive prescribing or dispensing of foot baths from independent pharmacies, prescribers, or among certain members/clusters
How can the Codoxo Forensic AI Platform assist your health plan with identifying emerging risks, trends, and other outlier claims for foot baths?
- The AI engine and detectors identify patterns, volume, and frequency across all peer groups and claims allowing customers to identify, analyze and respond to potential FWA and efficacy issues
- The Query tool allows users to build custom queries, tailored to their organizational needs
If you are an existing customer, please contact your Customer Success representative or
support@codoxo.com for assistance with this topic. If you would like more information or to set up a demonstration of the Codoxo Forensic Platform, please contact
sales@codoxo.com.
Foot Bath References
Mayo Clinic,
MRSA Infection Overview
https://www.mayoclinic.org/diseases-conditions/mrsa/symptoms-causes/syc-20375336
Blue Peak Advisors,
CMS Fraud Conference – Working Together to Combat Fraud, August 2, 2019
https://bluepeakadvisors.com/cms-fraud-conference-working-together-to-combat-fraud/
