Mitch, you’ve asked a ‘gotcha’ question. I’m quite certain that your fiscal intermediary will be asking the same questions that I am ... so, let’s start.
First, you said that the course of hyperbaric oxygen ‘healed’ the ulcer in the right foot. The question is ... was the ulcer documented as healed? Was there really skin covering the ulcer, no wound visible?
Second, how long after the ulcer ‘healing’ was the osteomyelitis noted? And, what is the location of the DFU vs. the osteomyelitis? Here’s the point of this question. Let’s say that the ulcer is a common hallux ulcer over the first metatarsal pad ... Now, your osteomyelitis just happens to be on the head of the first metatarsal ... This is just too convenient to be happenstance.
Third, define osteomyelitis for me. Here is my definition in order to be eligible to treat for HBOT. The osteomyelitis must be debrided surgically and bone specimen sent to pathology for micro studies. I’m not too particular about getting an absolute diagnosis, in fact that rarely happens. Next comes advanced wound care and at least 6 weeks of appropriate IV/systemic antibiotics. After that, with documented resolution of CRP and sedimentation rates ... then, and only then, (and only when the osteomyelitis returns) has the patient satisfied my criteria for adjunctive HBOT with osteomyelitis.
So, how about some answers, then we can go from there.
Your question about numbering ... yes, if the patient has a new diagnosis, he/she has a new #1 of X for me.
Finally, documentation of all of the above in the patient chart would be key to keeping you out of the fraud and abuse realm. You will likely be audited, and your documentation must support what you are claiming.
Now, I’ll show my bias. The situation that you asked just doesn’t happen clinically. I won’t say “NEVER,” but I will say ‘rarely’ ... The alternative situation is that the osteomyelitis was there all along and now ‘discovered’ by the physician. Just a thought.