The cost of noncompliance is greater than you think. The statistics paint a disquieting picture. In the October 2. Office of Inspector General OIG report, it was estimated that 8. CMS rules in one way or another. The amount of overpayments to DCs was estimated to be approximately 3. And almost every day in the news you can find reports of a chiropractor arrested for some type of fraud or abuse of third party payers. In Florida this year, for example, a DC was sentenced to almost 1. Also this year, a New Jersey chiropractor was arrested for being part of a scheme that directed patients to specific radiology centers in exchange for kickbacks. Again in New Jersey, another DC has been arraigned on charges of healthcare claims fraud, conspiracy, and commercial bribery for a massive criminal operation that involved dozens of participants ranging from DCs to MDs to clinic operators who took bribes to refer patients to an MRI center. Atlas Chiropractic Software System' title='Atlas Chiropractic Software System' />Welcome To the solutions Only Answer to Cancer. ONLY ANSWER TO CANCER. Excerpt from Dr. Leonard Coldwells Books. ChiroFusion is a fully integrated, cloudbased chiropractic software that includes SOAP notes, scheduling, billing software and more for only 99. These cases involved amounts ranging from the tens of thousands to the millions of dollars and are typical of the kind of misconduct auditors are paid to find. Pay attention. A key distinction here, however, is that the 8. Gmail is email thats intuitive, efficient, and useful. GB of storage, less spam, and mobile access. From millions of real job salary data. Average salary is Detailed starting salary, median salary, pay scale, bonus data report. OIG is not pointing at only DCs committing egregious, willful violations of the law. Rather, the majority of what it deemed improper payments were arguably due to carelessness and ignorance of the rules. Such cases are avoidable and the wise doctor of chiropractic will take steps to ensure that his or her billing and documentation are compliant and accurate. By now youve surely been told that you should conduct a practice self audit, or consider having a professional do one for you. Background Bed rest and backextension exercises are often prescribed for patients with acute low back pain, but the effectiveness of these two competing treatments. In the October 2016 OIG report, it was estimated that 82 percent of payments made in 2013 achieved chiropractic noncompliance with CMS rules. DOC0LjYU8AAs3nc.jpg' alt='Atlas Chiropractic Software System' title='Atlas Chiropractic Software System' />In addition, you know you should have a compliance manual. Yet often as not, discussions of compliance tend to end hereand this is a mistake. A binder gathering dust on a shelf is not a compliance program. Rather, you should think of compliance as being a dynamic and ongoing process, a style of practicing with an ever vigilant focus on avoiding danger. Red flag realities. Just a decade or two ago, you could assume the risk of an audit was small, given that a human would have to spot problems in your paperwork and initiate a review. Torchlight 2 Activation Key'>Torchlight 2 Activation Key. Today, though, computer algorithms are continuously comparing your practice to that of your peers. Anything you do that isnt normal in this context is potentially a red flag that can bring you under closer scrutiny. In 2. OIG stated that everyone needs written rules, says Kathy Mills Chang, MCS P, a coding and compliance expert. She points to the following four areas identified by the OIG as posing particular difficulties for DCs Poor documentation. Documentation of medical necessity. Coding. Patient finance inconsistenciesJust because youre getting paid doesnt mean youre billing correctly, Chang says. When you sign on line 3. I hereby swear Im following the rules. Its like filling out your taxes. Every chart tells a storyOn a claim form, we report to a third party what we did, says Evan Gwilliam, DC, CPC, a certified coding expert and trainer. The ICD 1. 0 diagnosis code says what happened to the patient, and the CPT code says what we did to treat it. When these two items are linked, they tell the story of what you did and why you did it. Take CPT code 9. 89. And consider a case where you are treating the knee. The insurer will go back to the ICD 1. M9. 9. 0. 6 segmental and somatic dysfunction of lower extremity, the story will make sense. If you get sloppy on the claim form and use the wrong diagnosis code, it wont be payable. This is an issue we see frequently, Gwilliam says. The person on the payers side only sees your claim form, not your notes. Thus it should tell a coherent story so that there is no need for a claims review. A matter of necessity. One issue the Centers for Medicare and Medicaid Services CMS and the OIG have underscored repeatedly is the question of medical necessity. Whether the condition you are treating is chronic or acute, there has to be a presenting problem you are coding for and the subject of a patient complaint. Failing this, in the eyes of the payers you may be providing non reimbursable wellness or maintenance care. So how do you ensure you have established medical necessity to treat a patient According to Gwilliam, the following formula should keep you on firm footing, provided you can answer each statement affirmatively Is there is a problem or complaint consistent with a conditionIs there a clear explanation for the complaint Is the treatment appropriate for the diagnosis and phase of the condition For example, in the chronic phase of care are you applying ice That would be a Is the patient progressing toward a resolution Will there be a measurable outcomeBasically, you can pick any service, exercise, electro stim, and if these four criteria are met, it should be considered medically necessary by any payer, Gwilliam says. Medical necessity has to be documented in your notes. With Medicare, especially, you need to know when youre crossing the line from necessity to maintenance. Some DCs think you cant go past 1. Deborah Green, Esq., a lawyer who specializes in healthcare law. But if you think a treatment is medically necessary, and you can prove that by administering more treatment that is required, has a beneficial effect, and improves the patients functioning, and you can document that, you should be able to obtain authorization from Medicare to go past 1. Its hard to believe, but there are DCs out there who dont take these matters seriously. Chang recalls one doctor in particular The documentation in his case didnt match what he was billing for. There was no treatment plan, no diagnosis. You dont even have a prayer of getting through an audit in a case like that. Going back to Gwilliams formula, your documentation has to tell the following story in a compelling way Is there a complaint Can I explain it Can I treat it Am I making progress with the patientThis causal chain explains the medical necessity. When we find a doctors whos having problems, we discover one or more elements of the causal chain have not been documented, Gwilliam says. Up to code. Typical coding problems Chang sees are cases such as when a DC is billing a large number of codes, and billing them together And CPT code 9. Championship Manager 2006 Full Game'>Championship Manager 2006 Full Game. In this case, it would need to be substantiated with a separate diagnosis for all five areas of the spine, and not apply to a chiropractic adjustment on the full spine performed for maintenance. Atlantica Server Files here. She has also noted problems arising when a DC bills for four units of exercise at a time, billing them together, or patterns of overutilization, where a DC is keeping a patient in active care and not transitioning them to a plateau or maintenance phase. If the typical DCs treatment plan is eight visits over the course of a month, and youre seeing patients for six to eight months at a time in active care, youre likely to come to somebodys attention. Thats not necessarily a problem. Its about profiling, Gwilliam says. The federal government looks at who is in compliance. They look at claims data to see who is an outlier. Gwilliam tells people thats its OK to be an outlier. You just have to be ready to prove the medical necessity of your treatments. You can see a patient as long as its medically necessary, even up to 3. Make no mistake, what hes getting at is that your documentation has to provide a convincing narrative about what youre doing.