Screening exam or not?

Great question and the answer is it depends.

If this is a non fee for service Medicare it may likely be covered as some have four visits a year free of co payments and they will pay for this. Same for other private and Medicaid payers.

For Traditional Fee for Service (TFFS) Medicare this is a bit trickier. If while examining the patient you find even a minor positive finding (mild autonomic neuropathy) with xerosis, that is a clinical finding which would be covered under MDM and the management would be to reccommend some OTC or Rx moisturizer, discuss foot hygiene measures etc.

Thus there is both an ICD10 and CPT associated with this.

In other words if you find someting that is BOTH evaluated and managed, then its possible the patient may have no chief or initial complaint, yet this would still be considered reimbursable.

An additional thought is if the patient has even a minor loss of protective sensation, then these visits can be billed under the Loss of Protection policy.

See https://med.noridianmedicare.com/web/jeb/specialties/podiatry/foot-care-for-patients-with-chronic-disease