CMS Issues Temporary “K” Code to Describe Direct Milled, Custom Fabricated Diabetic Inserts

On January 11, 2018, as part of its quarterly HCPCS update, the Centers for Medicare and Medicaid Services (CMS) issued a new HCPCS code to describe direct milled, custom fabricated diabetic inserts.  The new code is effective April 1, 2018 reads as follows:

K0903–For Diabetics Only, Multiple Density Insert, Made By Direct Carving With CAM Technology From A Rectified CAD Model Created From A Digitized Scan Of The Patient, Total Contact With Patient’s Foot, Including Arch, Base Layer Minimum Of 3/16 Inch Material Of Shore A 35 Durometer (Or Higher), Includes Arch Filler And Other Shaping Material, Custom Fabricated, Each

The new code is categorized as a “K” code which is technically a temporary code designed to allow CMS to track utilization prior to deciding whether to issue a permanent HCPCS code, in this case an “A” code.  Any codes that are created mid-year must be issued as “K” codes.

The purpose of the K code is to differentiate between custom fabricated diabetic inserts that are molded over a physical model of the patient’s foot (A5513) from those that are direct milled based on a digital or virtual model of the patient’s foot.  While both manufacturing processes result in functionally identical custom fabricated, total contact inserts, CMS has indicated that direct milled inserts, while qualified to meet the DMEPOS Supplier Standards definition of molded to patient model, do not meet the requirements of A5513.  AOPA has challenged this premise and is continuing to discuss this issue with high ranking CMS officials.

A fee schedule for K0903 has not been released.  CMS has previously indicated that Medicare reimbursement for direct milled inserts would be 14% lower than the current reimbursement rate for custom molded inserts described by A5513 due to the lack of creation of a physical model of the patient’s foot.  AOPA disagrees with CMS on this issue and provided extensive comments regarding reimbursement for direct milled inserts in its formal submission to CMS.

AOPA will continue to follow this issue closely and will provide additional information upon its release by CMS.

Questions regarding this issue may be directed to Joe McTernan at or Devon Bernard at