Healthcare professionals—if you’re in podiatry and treating patients with systemic conditions like diabetes, you already know how complicated insurance billing can get. This is especially true when those patients have coexisting conditions like diabetic retinopathy or glaucoma that impact overall care plans. Although ophthalmic implant codes aren’t typically part of podiatry billing, confusion sometimes arises when managing care for complex patients.

This post draws from trusted sources like CMS.gov, the American Academy of Ophthalmology (AAO), and payer resources, including Anthem’s published policies. Let’s break down what you need to know about previously used ophthalmology codes like CPT 0191T, what replaced them, why denials happen, and what practical steps can help reduce billing headaches. We'll also include common denial codes (CARCs and RARCs) you can spot and address efficiently.

Quick Primer: What Happened to CPT 0191T?

CPT 0191T was a Category III code used for the insertion of an aqueous drainage assist device (without an external reservoir) into the subconjunctival space, typically during minimally invasive glaucoma surgery (MIGS). It was primarily associated with procedures involving stents to manage intraocular pressure in glaucoma.

However, as of January 1, 2022, the American Medical Association deleted CPT 0191T. It was replaced by more specific Category I and III codes, including:

• 66989 – Cataract surgery with insertion of an aqueous drainage device
• 66991 – Complex cataract surgery with aqueous drainage device
• 0671T – Standalone insertion of aqueous drainage device (without cataract surgery)

Use of 0191T after its deletion may result in claim rejections unless you’re correcting a historic claim within a valid timely filing window. As of 2025, current ophthalmic billing must use the updated CPT codes for stent or implant procedures.

Important Clarification: Ophthalmic Device Codes Aren’t Billable by Podiatrists

Let’s be clear: while patients with diabetes and retinopathy may require both ophthalmologic and podiatric care, there’s no scenario under CMS or Anthem policy where a podiatrist would directly bill for an ophthalmic implant like those described by 0191T or its successors.

That said, it’s common for denials to occur in diabetic foot care if the documentation doesn't support medical necessity—especially in the absence of qualifying systemic diagnoses such as:

• E11.9 + L97.4X – Unspecified diabetes with non-pressure ulcer of foot‍
• E11.51 – Type 2 diabetes mellitus with diabetic peripheral angiopathy
• E11.42 – Type 2 diabetes mellitus with polyneuropathy
  

In rare circumstances, diabetic retinopathy (e.g., E11.351) may be relevant in overall risk assessment but does not justify billing an ophthalmic procedure code on a podiatric claim.

Common Issues Leading to Anthem Denials (Even Without 0191T)

Anthem follows CMS-aligned rules with their own internal edits and reimbursement guidelines. Denials for diabetic foot care or other routine podiatry services may result from:

1. Lack of Medical Necessity Documentation

Anthem may deny claims when there’s no qualifying ICD-10 diagnosis or if progress notes don’t establish the systemic condition impacting foot health. Be sure documentation links foot care to covered conditions like diabetes with neuropathy or ischemia.

2. Incorrect or Outdated CPT Codes

Using deleted codes like 0191T will almost always result in a claim rejection (CARC CO-16: Missing or invalid information). Always verify that procedure codes are current.

3. Modifier Errors

Modifier ‑25 (for significant, separately identifiable E/M) or ‑59 (distinct procedural service) may be necessary when billing debridement (e.g., CPT 11056) alongside E/M or other services. Incorrect or missing modifiers often lead to bundling denials.

4. Routine Foot Care Not Covered

Routine care such as nail trimming or corn/callus removal is not covered unless medically necessary. Anthem’s foot care policy (CG-MED-92) outlines what qualifies.

CARC and RARC Examples: How to Decode Anthem Denials

Strategies to Avoid Denials and Get Paid Faster

Here’s a streamlined checklist to improve claim success:

• Verify Coverage and Benefits: Use Anthem’s provider portal or Availity to confirm medical necessity and check benefit eligibility before the appointment.
• Use Current CPT and ICD-10 Codes: Retired codes like 0191T should no longer appear on claims. Use appropriate replacements based on service type.
• Include Strong Documentation: Tie foot care clearly to systemic conditions. Use progress notes and risk assessments to justify treatment.
• Apply Modifiers Correctly: When billing multiple procedures, apply appropriate modifiers (e.g., ‑25 for E/M, ‑59 for procedure bundles).
• Train Billing Staff Regularly: Keep your team informed of code changes, Anthem policy updates, and quarterly ICD-10 revisions.
• Appeal With Supporting Evidence: If denied, resubmit within Anthem’s 180-day window with corrected codes, full chart notes, and reference policy excerpts.

Final Thoughts: Keep It Clean, Keep It Current

The bottom line? While CPT 0191T is obsolete and not applicable to podiatry billing, you can still protect your reimbursements by aligning your documentation, diagnosis coding, and procedural coding with CMS and Anthem’s current rules.

When dealing with complex diabetic patients, build your claims around what is medically necessary and covered—not around unrelated codes from other specialties. As always, check CMS.gov and Anthem’s provider portal for the latest coverage guidelines.