Newsletters from June 2011

June 2011

June 3, 2011
Chiropractic Medicare Compliance

What do the typical Chiropractor and their staff need to do to become compliant in the future Medicare arena?

Relax!  Sit back and review materials as they are presented.  I recommend not spending big bucks for software right now.  Remember the rules for becoming compliant are still being discussed with many unanswered questions.

We have two important Medicare issues to understand.  First, learning and doing Chiropractic Medicare so our patients receive their needed Chiropractic adjustments.  Secondly, doing Chiropractic Medicare correctly with proper procedure, S.O.A.P. notes and documenting the Chiropractic necessity of care so when audited, either in house or by your Medicare Carrier, you are successful. By doing Medicare correctly, once you have become compliant, your in-house audits will reveal you do, in fact, know how to do Medicare correctly. 

Most important, be sure you know how to do Medicare correctly.  If you are not sure, consider our Chiropractic Medicare DVD and booklet. Once you are actively improving your record keeping and documentation, now consider becoming Medicare Compliant.  First move, you should appoint a Compliance Officer for your Chiropractic Business. (You or one of your Staff)  The Compliance Officer's job is to start collecting information for implementing proper procedures to make your office compliant.  In the next few weeks we will have a Chiropractic Medicare Compliance Guidelines Booklet available for our fellow Chiropractors and staff.

Remember.....everyone has to do this, so keep it as simple as possible and keep on going. 

June 10, 2011
"Unusual payments and X-ray vs. P.A.R.T"

The past couple of weeks our patients and many doctors are receiving checks and direct deposits from the Medicare carriers in the amounts of around $1.60 for adjustments provided in early 2010.  Those checks and deposits represent the fee changes that occurred in 2010.  Many patients do not understand why they receive this money.

NOTE - We constantly get the question... "Must I take x-rays of the regions of the patient adjusted each 12 months?"

ANSWER - If you use an x-ray to prove a subluxation, YES, you must have x-rays of all the regions you adjust and those films must be less than 12 months old.

If you chose to not take an x-ray on your Medicare patients each 12 months, you can complete a P.A.R.T. form each visit.  Using x-rays to prove the subluxation is by far the best.  You are the authority of information you find on the x-ray.  Using a P.A.R.T. form is not as effective and safe simply because anyone else can review the P.A.R.T. form and may determine something different than you.

June 14, 2011
"PI & Medicare"

When a Medicare patient enters your office that has been in an auto accident, remember, they are still a Medicare patient.

If you are a non-participating provider, you must not bill the PI Insurance Company above the limiting charge set by your Medicare Carrier.  As a participating provider, you can bill your normal PI fee.

The Medicare patient should sign an ABN each visit so they are aware Medicare will not pay for any services.  When billed to the PI Insurance, the AT modifier is also used indicating "Active Treatment".  Example:  98941 AT GA.  The GA modifier is used if the patient signs an ABN for a covered service and a GX modifier is used if the patient signs the ABN for any non-covered service in

Medicare. Item 10a thru 10c on the claim, when completed, tells the PI Insurance Company that it is their responsibility.  The Medicare Carrier should pay nothing on this claim, unless the PI Insurance Company wins the case and pays nothing.
You can now take the denial letter from the PI Insurance Company, mail a copy to Medicare, and Medicare will now pay the claim.

IMPORTANT:  If for some reason, Medicare pays on this PI case, and the PI Insurance also pays, if you do not refund the money back to Medicare within a specific time, Medicare will take that money out of your (The Doctors) Social Security account.

June 20, 2011
"Do you have a Medicare Compliance Plan?"

Years prior, violations were limited.  However, now violations are staggering and enforcement carries major disabling fines.  Willful neglect is simply not knowing, or knowing and doing nothing.  The time of sitting back, going with the flow and doing/knowing nothing is over.

It is mandatory to have an in-office compliance program.  Your office will need a HIPPA Privacy Officer, HIPPA Security Officer and a Compliance Officer.  These are the three people asked for in an audit.

Here are the five best ways to come up with an audit:

1. Disgruntled Employee - usually comes with a filed complaint.




2. Patient Complaint - usually from billing error or patient misunderstanding.




3. Doctor Complaint - usually from questionable advertising, waiving copayments, etc.




4. X-ray Practices - most of the time while using outside x-ray facilities.




5. Errors in billing or suspicious billing practices, CMT’s, coding, etc.

If you find an in-office error, do not hesitate refunding the carrier before your carrier finds the error.

Finally, each office must have a written Policy and Procedure Plan for open line in-office communications.

We soon will have an example OIG Compliance Plan that will be available.  In the meantime, be sure you are doing Medicare correctly.  All of this and much more can be found in our Chiropractic Medicare DVD.  Thank you for your interest.