IMPORTANT DEADLINE 12-12-12 FOR PQRS

Newsletter
December 11, 2012
IMPORTANT DEADLINE 12-12-12 FOR PQRS
(Physician Quality Reporting System)

 

The Chiropractors in our Chiropractic profession have worked for over 100 years to help Chiropractic grow and be accepted by the public. We have been very successful in being included into insurance plans, Medicare, Medicaid, PPO's, etc. However, now that we are in Medicare we have to meet qualifications and demands by the Federal Government to take part in reporting certain quality measures due to healthcare reform.

Please see link to the CMS Website for more information about PQRS (Physician Quality Reporting System):
 https://www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/PQRS/downloads/2012PQRS_SatisfRprtng-Claims_Final508_1-13-2012.pdf

To determine if you are eligible to participate in PQRS:  
https://www.cms.gov/PQRS

Even though it is a voluntary program with incentives, it is also a program that will take away from your future earnings if you do not participate.

My guess is about 5 Chiropractors out of every 25 are participating in PQRS. This is NOT A GAME! This is serious business! We are going into the final window of opportunity.

The Physicians Quality Reporting System (PQRS), was introduced by the Centers for Medicare and Medicaid Services, and a new part of healthcare reform. The program created in 2007, established a financial incentive to eligible healthcare professionals to participate in a voluntary quality reporting program. Providers who participate and report quality measures receive a 0.5% payment incentive.

Why is it so important? CMS recently ruled that providers not successfully participating in PQRS by 2013 reporting period (January 1 - December 31, 2013), will have their Medicare reimbursement decreased by 1.5% beginning in 2015, and 2% in 2016. The 2012 reporting period is the last opportunity providers have to voluntarily participate.

It is easier than you think. However, it requires a certified software company to walk you through the paces. Please follow the links and get informed.

Treatment Plans

Newsletter

14-Nov-12

"Treatment Plan"

Seminar Dates:

11-29-12 Pacific, WA - King Oscar Hotel, 8:30 am to 12:30 pm

11-29-12 Everett-Mukilteo, WA -Staybridge Suites, 6:00 to 10:00 pm

12-1-12 Portland, OR - Holiday Inn, Airport, 8:30 am to 12:30 pm

12-8-12 Orlando, FL - Clarion Inn & Suites, 8:30 am to 12:30 pm

As we review audit after audit reports, the "treatment plan" seems to be high in failure rate by fellow Chiropractors. Without a treatment plan, reimbursement can be a failure, especially after record requests by both Medicare Carriers and Insurance Companies.

"Treatment Plan to Consider"

Scenario: A new patient enters your office, his age is 79, raking leaves and receives a sharp shooting low back pain upon lifting a bag of leaves.

The patient completes all new patient forms and seated across from you for consultation. He indicates he is basically healthy and hardly ever has back pain. You have decided to accept this patient and proceed doing a case history, examination, spinal x-rays (1-14x36 AP, 1-7x17 Lat. thoracic, 1 7x17 Lat. lumbar and 1-8x10 Lat. cervical) and perform a scan prior to the patient reporting to your appointment area to set an appointment for a report of findings in 2 hours or tomorrow. The patient pays for today's services and leaves.

To prepare the report of findings, x-rays are developed and analyzed, examinations reviewed, reports are completed and a treatment plan is now produced. For this Medicare patient, we will have a dual treatment plan developed.

1. The Original Treatment Plan, to see this patient 3 times a week for 3 weeks, 2 times a week for 4 weeks and 1 time a week for 5 weeks and a re-evaluation in 90 days.

2. The Documentation Treatment Plan can also be used because this patient experienced an exacerbation in which soft tissue in a predisposed old arthritic subluxated joint was injured, torn, stretched, bleeding, etc. This finding, supported by x-rays, is an exacerbation that when "documented" correctly, is worth 1 to 6 visits as approved by Administrative Law Judges.

*You will most likely use the Documentation Treatment Plan for 1 to 6 visits. However, our senior patients are the most active patients in our practice. About their 5th visit, they have a new exacerbation. You will again produce "Documentation" indicating 1 to 6 visits on the new treatment plan. This process continues with this Medicare patient and many times the original treatment plan is never used. This "Document" which is critical in Medicare, can be produced with many software  programs as we work our way to becoming "paperless".

More Compliance

Newsletter

November 6, 2012
Chiropractic Medicare & Compliance

Just a small reminder:

No matter where I speak, in the Eastern States or Western States, North or South...I still run into fellow Chiropractors who do not seem to be aware that it is a federal law as per Social Security Act (Section 1848(g)(4)) that when they adjust a Medicare patient, it is  mandatory claims submission in a reasonable amount of time (one year or less).

If you have no Medicare number and/or have not completed a CMS 855i application, you are not qualified to file a Medicare claim to a Medicare Carrier. This also means you are not qualified to take care of a Medicare patient. If you are adjusting Medicare patients and not billing Medicare for your patient, you have breached the federal law and may be fined up to $10,000.00 per adjustment.

The simplest of all rules in Medicare is being overseen by a surprising number of chiropractors. If you know any that are not billing Medicare, please confront them, as you may save them big dollars and embarrassment.

We all must keep in mind that our seniors in the Medicare program pay premiums each and every month. It is our job to document and bill Medicare so correct reimbursement is part of the normal Medicare process.

NOTE: We must know how to do Medicare to keep out of trouble and make sure our seniors are reimbursed. We also must become Medicare Compliant to stop fraud and abuse. Your compliance in your office should be nearly completed by now. For the required seven (7) categories we must respond to by creating a Medicare Compliance Program and procedures in your practice, follow this link: http://www.cms.gov/Medicare/Medicare-Contracting/MedicareContractingReform/Downloads/compliance.pdf

 

Have questions? Give Dr. Street a call today at (618) 395-3800.

Florida, Oregon, and Washington ~Newsletter 10/29/2012

Newsletter

October 29, 2012

Chiropractic Medicare Seminar Dates:

11-3-12     Wenatchee, WA - Wenatchee Conference Center, 1:00 pm to 5:00 pm.

11-10-12   Chicago, IL - Guest speaker at the Simplify Conference (Chirotouch) Postponed

11-29-12   Pacific, WA -  King Oscar Hotel, 8:30 am to 12:30 pm

11-29-12   Everett-Mukilteo, WA-Staybridge Suites, Mukilteo/Everett, 6:00 to 10:00 pm.

12-1-12     Portland, OR - Holiday Inn, Airport, 8:30 am to 12:30 pm

12-8-12     Orlando, FL -  Clarion Inn & Suites, 8:30 am to 12:30 pm

Chiropractic Medicare & Compliance

Florida Chiropractors and Staff:

     Of all the Important Chiropractic issues, Medicare hits the top of your important list.  You have nearly the highest number of seniors residing in your state and they need and deserve Chiropractic care.

     On Saturday, December 8th, I will be at the Clarion Inn and Suites, Orlando, 8:30 am to 12:30 pm covering critical information for Chiropractors and their staff.  In this 4 hour presentation, I will cover everything from the important ABN to becoming Medicare Compliant, going paperless, and the Medicare Electronic Health Record (EHR) Incentive Program to get money back from the government.

     This information is critical if you wish to be in Chiropractic practice in 2015.  The program registration fee is low, the presentation is fun and very informative, plus by attending, you will receive a CD containing important information you can use in your office.

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     This coming weekend, Saturday, November 3rd, I will be speaking with Chiropractors and Staff in Wenatchee, Washington for Dr. Brad Summers.  The presentation is from 1:00 to 5:00 pm.  However, I will be back in the state of Washington on Thursday, November 29th, morning in Pacific and the evening in Mukilteo/Everett.

Have questions? Give Dr. Street a call today at (618) 395-3800.

Learn, Compliance, Paperless & Attestation

Newsletter
October 22, 2012
Chiropractic Medicare
Learn, Compliance, Paperless & Attestation
Now is not the time to procrastinate!  If you plan on being in Chiropractic practice in 2015....listen up!  You have a choice.  Either get with it or get ready to retire!

Now that I have your attention, here are the steps necessary to wade through this Medicare process.  The process is not as extreme as first impression. 

1. Learn the correct way to do Chiropractic Medicare.  If you do not do Medicare correctly, all else will not be effective.  If you have attended our presentation or have our Chiropractic Medicare DVD & booklet, review the DVD and start doing Medicare correctly.
2. The Federal law says we must become Medicare Compliant. Follow this link: http://www.cms.gov/Medicare/Medicare-Contracting/MedicareContractingReform/Downloads/compliance.pdf  They provide seven (7) categories we must respond to by creating a Medicare Compliance Program and procedures in your practice.
3. Electronic Billing and Going Paperless
1. Nearly all Chiropractic offices are billing Medicare electronically. If you are not, you are going to be left behind and soon will be cut in Medicare reimbursement. Call your Medicare carrier, ask the carrier to help you bill electronically and follow their guidelines. Do not put it it off another day.
2. Going paperless is fabulous as long as you have a good Chiropractic software in your practice. I use Chirotouch software. This software leads you through the process of becoming paperless. I have to say, after doing written notes for forty-four (44) years, it is absolutely great to make a few clicks on the computer and not only have S.O.A.P. notes completed, but also produce "Documentation" by Federal Standards for Medicare, PI, etc.
4. Attestation: Once you have used and learned the software and follow the specific programs in the software, you will be ready to "attest" as to following the guidelines of a paperless practice. The government will now pay you an incentive dollar amount in direct proportion as to the number of Medicare visits you have. Learn more about the EHR Incentive Program. Remember....only the use of Certified EHR (those that meet specific federal standards for Meaningful Use) can qualify for incentive payment.  Do you know if your software is qualified? Follow this link: http://oncchpl.force.com/ehrcert

Have questions?
Give Dr. Street a call today at (618) 395-3800.

      

Chiropractic Medicare Federal Guidelines

Newsletter

October 8, 2012

 Chiropractic Medicare

Federal Guidelines and

Seminar Dates: Washington, Oregon, and Florida!

 

 Medicare carriers across America, with the approval of CMS, have and are doing the job on chiropractic care. First, they have led chiropractors away from that inwhich chiropractic is all about, locating and correcting vertebral subluxations.

 

The Federal Guidelines click or follow this link to CMS (Medicare) website:

 http://www.cms.gov/Regulations-and-Guidance/Guidance/Manuals/downloads/bp102c15.pdf

 

The Federal Guidelines indicate the primary and ONLY job of a chiropractor in Medicare is to locate and correct vertebral subluxations. Back in 1973 we were mandated to take x-rays to prove the subluxation and once proven, we were reimbursed to adjust those subluxations. There was and still are NO limits in Medicare for the chiropractic adjustment.


Over the years the Medicare carriers have led the chiropractors down the yellow brick road of “treating” patients symptoms. Developing a “treatment plan” specifically related to the patient’s symptoms and NOT related to the correction of a vertebral subluxation which is indicated by Federal  guidelines.


Now the past years statistics on chiropractors indicate chiropractors treating patient symptoms are doing a poor job of documenting the necessity of treatment care so the Medicare carriers believe we are billing for maintenance care since most chiropractors have no idea the correct way to “document” the chiropractic care necessary.


Chiropractors should practice like chiropractors. Use the patient’s symptoms for diagnosis, locating the problem and decision making, but do not “treat” patient symptoms. There are plenty of other health care provider that ONLY treat symptoms.


Consider this scenario: New 74 year old patient comes into your office for chiropractic care after picking up a box at home hurting his low back. You do the workup including exam and x-rays and find a subluxation of L5. It has only been there 35 years….. you know that because it has proliferating arthritis that has been developing for the past 34 years because he never got it corrected. The L5, S1 articulations has soft tissue insult, swelling, etc., indicating sprain/strain. (diagnosis: 739.3, arthritis, sprain/strain)

This is an exacerbation on a new patient, soft tissue tear in a predisposed chronic subluxated, degenerative joint. By “documenting” this specific event correctly, this exacerbation is worth up to 6 visits. However, if chiropractors listen to our patients and understand the most active patient’s in your practice are your seniors, you will soon find your seniors have all kinds of exacerbations. Your job is to locate the subluxation, document the exacerbation by Federal Guidelines and correct subluxations.

 

Many Medicare carriers across America have stepped up and set specific visit guidelines for Medicare patients. Even though the Federal chiropractic guideline says there are no limits in Medicare for the chiropractic adjustment.

 

If you are in one of these states, (Tennessee, New Jersey, etc.) and you do chiropractic Medicare correctly and meet your carrier limit, go through the appeals process. Once you get to the Administrative Law Judge, if you have done your job like you have learned in our presentation or DVD, you should have a positive return from the ALJ.

 

QUESTIONS OR COMMENTS? Please give me a call.

 

Warmest regards,

Gary R. Street, D.C.

400 S. West Street

Olney, IL 62450

1-800-MY CHIRO

drgrstreet@nwcable.net

www.chiropracticmedicare.com

www.youtube.com/DrGRStreet 
 

Fall Seminar Schedule:

 

11/29/12

King Oscar Hotel, Pacific, WA 8:30 am to 12:30 pm

 

11/29/12

Staybridge Suites Mukilteo-Everett, Mukilteo, WA, 6:00 to 10:00 pm

 

12/1/12

Portland, Oregon Medicare Presentation 8:30 am to 12:30 pm

 

12/8/12

Orlando, Florida Medicare Presentation 8:30 am to 12:30 pm

"Becoming Compliant"~Newsletter 09/17/2012

Newsletter

September 17, 2012

Chiropractic Medicare

     1. Stopping Fraud & Abuse

2. Becoming Compliant

    3. Going For the Incentive

The government strategy of becoming compliant in Medicare, going paperless and getting an incentive to do so, is and will be effective in stopping fraud and abuse in Medicare.

One small problem.  Much of what the government calls abuse is not abuse.  It is the inability of Chiropractors to "Document" the Chiropractors necessity of care by "Federal Standards."

Since Medicare Carriers do not have the ability...(or do not want to)...review Chiropractic claims when they receive them......  ALL clean claims are automatically paid.  However, then companies are hired by the Medicare Carriers to reclaim money from Chiropractors that do not do Medicare correctly.

When doing Medicare you must know how to document the Chiropractic necessity of care by "Federal Standards".  Since most Chiropractors have never been shown or told how to "Document", a lot of money is recovered by these hired groups. The federal government calls this abuse against Medicare because the Chiropractor billed Medicare for a service that did not have documentation for payment that the government believes should have been billed as Maintenance Care.

Money is recovered by the hired firm, the Chiropractor has to pay it back, and statistics call that Fraud and Abuse against Medicare....simply because the Chiropractor did not know the correct way to do Medicare!

FIRST:  Learn how to do Chiropractic Medicare correctly.

SECOND:  Become compliant.

Finally....Contact your software company in regards to receiving incentives. We like Chirotouch.

REMEMBER: You are required to become Medicare Compliant prior to 2013.        December is coming quickly.

Federal Incentive Payments for Implementing Electronic Health Records (EHR)

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Newsletter

September 10, 2012

Chiropractic Medicare INCENTIVE

Federal Incentive Payments for Implementing Electronic Health Records (EHR)

Did you know Chiropractors are eligible for up to $44,000.00 each from Medicare? So far $16.5 million has been paid to Chiropractors.  Well over 2000 Chiropractors have been paid, some even the last installment.

You must Attest Meaningful Use in a continuous 90 day period within that calendar year.  In subsequent years, after a providers first year, the reporting period is the entire calendar year. For more information follow this link: https://www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/downloads/Beginners_Guide.pdf

In other words, you must register this month, so you have October thru December of this year for EHR Meaningful Use.  You can still be eligible to receive the full $44,000.00 incentive by implementing EHR in your practice no later than October 3, 2012 and performing meaningful use for just 90 days in your first year.

It makes no difference as to Participating or Non-participating Provider.  If you submit claims for Part B covered services, you are eligible.  If you successfully register and demonstrate meaningful use of a certified Electronic Health Record, your incentive payment will be based on all services allowed under Part B, regardless of your participation status or whether you have accepted assignment on those claims.

Remember....only the use of Certified EHR (those that meet specific federal standards for Meaningful Use) can qualify for incentive payment.  Do you know if your software is qualified? Follow this link: http://oncchpl.force.com/ehrcert

I am so fortunate to be using ChiroTouch software that has it together.  
Questions?  Give me a call (618) 395-3800.

The Federal Incentive Payments Program is helpful, but remember you must know the correct way to do Chiropractic Medicare and also become Medicare Compliant. Once the correct way to do Medicare is understood, you are half the way. 

REMEMBER....
You are required to become Medicare Compliant prior to 2013.        
December is coming quickly.  

"The Medicare Claim Tells the Story" ~Newsletter 8/20/12

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Newsletter
August 20, 2012
Chiropractic Medicare
"The Medicare Claim Tells the Story"

 

 Most of my fellow Chiropractors, when they call about an audit or pre-pay request for records, ask why they received the record request.  Most of the time they have a request for records because the items on the claim do not match.

 

 An example:  A claim with an acute diagnosis indicating an acute condition or an exacerbation may have in item #14, Date of Current, a date over 60 days.  This tells the carrier the condition is chronic so the doctor receives a request for records to verify the true story on the patient. 

Date of Current on an active patient should NEVER be over 60 days if your are expecting Medicare reimbursement.

 

 Or...the diagnosis only consists of a subluxation with maybe arthritis.  The carrier knows this patient can be adjusted twice a day for 6 months and an x-ray indicated a subluxation and arthritis.  No improvement and no reimbursement.  The diagnosis should have three parts to it.  An example: subluxation, arthritis and sprain/strain if there has been an exacerbation.

 

 If item #19 does not have both date of x-ray(less than one year) or P.A.R.T., the claim may not be payable.  The carrier may ask for patient records to verify if the doctor proved a subluxation by either an x-ray less than one year or a P.A.R.T. form for each visit.  X-rays are mandated each year, if the doctor proves subluxation by way of x-ray. A P.A.R.T. form is mandated each visit if the doctor does not use x-rays to prove the subluxation.

 

Some carriers ask for office patient records periodically to verify if the doctor has a treatment plan with the three key components.  The "documentation" provided by our program consists of both "Federal Documentation" and also a treatment plan meeting all three components.

 

Many times the carrier will ask for patient S.O.A.P. notes to verify the doctor did in fact adjust vertebrae is specific regions in which they billed Medicare. If you adjust 4 regions on your patient for example, your billing will match the S.O.A.P. notes as to the number of regions you adjusted and billed to Medicare.

 

 Generally the information on each claim should all match.....diagnosis supports the care rendered, Item #14, date of current, is less than 60 days old, Item #19 contains date of x-ray or P.A.R.T., and specific terminology indicating any exacerbation and the "documentation" has been produced.

 

 Once the correct way to do Medicare is understood, you are half the way. 

"ABN - Important!" ~Newsletter 8/14/12

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Newsletter
August 14, 2012
Chiropractic Medicare
"ABN - Important!"

 

If a patient selects Option #2 on the ABN, the service indicated on the ABN does not then become a non-covered service.  However, the doctor does not have to file a claim to Medicare in that particular instance because the patient indicated that he or she agrees to pay out-of-pocket and does not want a claim submitted to Medicare. (However, the patient can change his or her mind, at a future time, and request the provider to submit a claim to Medicare.)  Both participating and non-participating providers are permitted to ask for payment from the patient at the time of service if either Option 1 or Option 2 is selected on the ABN.

 

It is my opinion that the purpose of the ABN, a rule that supersedes the Mandatory Claims Submission Law, is a simple attempt to supply a process to not bill Medicare for our seniors so the carrier's do not have to reimburse for Chiropractic adjustments.  That is a deceiving way to cheat our seniors from reimbursement in Medicare in which they have already paid, plus they pay a Medicare premium each month for coverage.  I strongly recommend we Chiropractors provide great Chiropractic care to the seniors, learn the correct way to do Medicare and bill Medicare so our seniors get their due reimbursement.

 

Remember...the ABN should only be presented to patients when the service in question may be denied by Medicare due to medical necessity.  It is not appropriate for the provider to present a patient with an ABN for a service that is expected to be covered.

 

The Chiropractic adjustment is ALWAYS a covered service by Federal Law and it is the responsibility of the Chiropractor to learn and provide "documentation" so the covered service is payable.

Newsletter 8/06/12 ~ "Back to the Basics"

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Newsletter
August 6, 2012
Chiropractic Medicare
"Back to the Basics"

 

The simple fact is "if you do not know how to do Chiropractic Medicare correctly...there is trouble!"  So most important....learn the correct way to do Chiropractic Medicare.

 

We have had the privilege of sharing, with our fellow Chiropractors and their staff, Chiropractic Medicare information for the past 34 years.  We constantly hear remarks like, "I have been in practice for 27 years.  Why didn't someone tell me this before now?" 

 

 You may believe you are doing Chiropractic Medicare correctly.  However, question yourself.  If you receive an audit today in the mail, what does your documentation look like? (Documentation is not S.O.A.P. notes.)  What does your treatment plan look like and does it have all three (3) required elements?

 

Questions? Please call me!  800-MY-CHIRO

"Audit....Notes of Interest" ~Newsletter 7/31/12

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Newsletter

July 31, 2012
Chiropractic Medicare
"Audit....Notes of Interest"

 

"Documentation" requirements for Chiropractic Care following the initial visit, these include:

1.       History:  Review of chief complaint.

a.       Changes since last visit.

b.      System review - if relevant.

2.       Physical Exam:

a.       Examination of area of spine involved in diagnosis.

b.      Assessment of change in patient condition since last visit.

c.       Evaluation of treatment effectiveness.

3.       Documentation of treatment given on day of visit.

 

NOTE:    Documentation cannot be used to substantiate medical necessity retrospectively.  In other words, documentation for medical necessity of care must be produced at time of visit.  Medicare guidelines require that medical need be established prior to providing the service at issue.  The medical record must stand on its own with original records supporting that the billed services is medically necessary and reasonable.

 

Those of you using our information, be sure to complete the "documentation" at time of visit.  If audited, include, with your documentation, the additional requirements listed at the first of this article.

ABN Discussion

Newsletter
July 23, 2012
Chiropractic Medicare

The basic purpose of Section 1879 of the Social Security Act, the limitation of liability provision (ABN) is to protect the beneficiaries (Patients) from liability in denial cases under certain conditions when items they receive are found to be excluded from coverage as NOT reasonable and necessary under section 1862 (a) (1) (A) of the Federal Security Act.

Where items or services are denied because they are determined to be not reasonable and necessary, the Medicare program makes payment when neither the beneficiary (patient) nor physician or supplier knew, and could not reasonably be expected to know, that the items or services were excluded.

When the beneficiary did not have such knowledge, but the physician or supplier knew, or could have been expected to know of the exclusion of items or services, the liability for the charges for the denied items or services rests with the physician or supplier.

If an ABN is not presented to the patient for those services or supplies that day prior to those services, the doctor will not be reimbursed by the Medicare Carrier if a participating provider and can not receive payment from the patient, or as a non-participating provider, the denial EOB will tell the patient to return to the doctor for a refund of what they paid at time of services. 

http://www.cms.gov/BNI/02_ABN.asp
http://www.cms.gov/MLNProducts/downloads/ABN_Booklet_ICN006266.pdf

The bottom line....the ABN is your friend.  You should make an assessment each office visit.  If you determine any service, covered or not, that you bill to Medicare may be denied today, you have the privilege of asking the patient to take financial responsibility by them signing an ABN today.

My Congressman's office called this morning.... Still waiting on CMS to give to me the official usage of option #2 on the ABN... keep watching.

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It is my goal to help Chiropractors and their staff understand Chiropractic Medicare so they are successful with Medicare, keep out of trouble, provide the adjustments our Medicare patients NEED, and bill claims correctly so we, not only stay in Medicare, but so Chiropractic will be included in future governmental health plans.

I am not a paid consultant.  I have excellent products containing information that may be purchased at a reasonable price.  I also believe in follow-up, so if you purchase some of our products, I will be available by phone or email to do my best to answer any questions you may have.
Thanks,
Dr. Street

If you do not have our information, you can visit our website or give us a call.  You will be so happy you have this information.

Still waiting on CMS to give to me the official usage of option #2 on the ABN... keep watching.

Remember....we all must become Medicare Compliant by the end of this year.

ABN Option #2 ~ Newsletter 7/2/2012

NewsletterJuly 2, 2012Chiropractic MedicareABN Option #2

Since posting my prior newsletters about ABN there has been considerable interests and questions  in regard to Option #2.

Option #2 on the ABN states, "I want the (Blank) listed above, but do not bill Medicare.  You may be asked to be paid now as I am responsible for payment.  I cannot appeal if Medicare is not billed.”

Option #2 is for ONLY non-covered services.

The Chiropractic adjustment is the only covered service for Chiropractors.

 National Government Services issued a "What's New" article on 6/27/12 with their explanation of the understanding of Option #2 as follows:

1. Option #2 of the ABN is to be used when a Chiropractor is providing a service to a Medicare beneficiary that is not going to be covered by Medicare.  The confusion has come in from some that believe Option 2 can only be utilized by the Chiropractor for the patient when the service is statutorily non-covered.  However, that is not the case.

2. The description for Option #2 indicates that the provider has told the beneficiary that Medicare will not cover the service because it does not meet policy criteria; therefore, it will be a non-covered service.  By selecting Option #2 the patient is authorizing that they still want the service to be performed and that they will pay the practitioner for the service.  Option #2 also alerts the beneficiary that a claim will not be filed to Medicare and that they have no appeal options.

3. The misunderstanding is that since the Chiropractic service is a Medicare benefit, just not covered for this specific scenario, that Option #2 should not be used.  The belief is that the Chiropractic adjustment is always a covered service; however it is not always covered, it is simply recognized as a Medicare benefit.  This also leads to the misunderstanding that Chiropractic adjustments must always be billed to the Medicare carrier for consideration.  With the implementation of the new ABN form, this is no longer the case.  Providers are allowed to provide a service to a beneficiary that they know will be non-covered by Medicare according to policy and the patient has the right to still have that service, pay the provider for that service and waive the filing of a claim to Medicare.

4. The Centers of Medicare & Medicaid Services (CMS) Internet-only Manual (IOM) Publication 100-04, Medicare Claims Processing Manual, Chapter 30, Section 50.14.1 (1.07 MB) states that in this situation the provider will not be violating "Mandatory Claim Submission" guidelines:

"Note:  Providers will not violate mandatory claims submission rules under Section 1848 of the Social Security Act when a claim is not submitted to Medicare at the beneficiary's written request in choosing Option #2 on the revised ABN."

If this is true, now the patient has the authority to mark Option #2 and it supersedes "Mandatory Claims Submission" and the "Participating Provider Contract" of not collecting the 80% of the fees at time of visit.  This also denies the patient from reimbursement for the covered service of the adjustment.  It also is another way cut Chiropractic reimbursement.

I am awaiting official explanation from CMS that I shall share as quickly as I receive.

Remember, we all must become Medicare Compliant by the end of this year!

Have questions? Give Dr. Street a call today at (618) 395-3800.

Please subscribe to my blog to have the latest newsletter and all my archived newsletters at your fingertips. Comments are encouraged!!

Keep in mind, Medicare is the only insurance type program that if done incorrectly is fraud, a felony, a fine and/or jail.

Resources and further reading:

http://www.cms.gov/Outreach-and-Education/Medicare-Learning-Network-MLN/MLNProducts/downloads/Chiropractors_fact_sheet.pdf

NGS pdf document  "869c_910_Notices_of_Noncoverage.pdf"

https://www.cms.gov/Outreach-and-Education/Medicare-Learning-Network-MLN/MLNMattersArticles/Downloads/MM7821.pdf

Beginning of JUNE Newsletters 2012

Beginning  of JUNE Newsletters

(Sent out June 4th, 12th and 18^th)

Chiropractic Medicare

Sent June 4^th, 2012

Dear Doctors and staff,

Those using our recommendations in doing Medicare are having great success when addressing pre and post payment reviews and audits.  I do not know another Chiropractic Medicare training program that uses the "documentation" we suggest.  The documentation used with our program is Federal Documentation and supports the Chiropractic truths in caring for seniors.  Once you see and understand our presentation you will realize its the truth and the way it is with seniors.

Until you understand how Chiropractic works with Medicare, several items on your claims will indicate to the Medicare carrier you do not have it together, which usually brings on reviews and audits.  We chiropractors do not "treat" patient symptoms.  Our only job is to locate and correct vertebral subluxations.  The lack of documentation (and documentation is not S.O.A.P. notes), date of current over 60 days old and/or a diagnosis that does not support the care rendered and this claim will "pop" out of the carrier's computer for review.

If the review reveals the doctor does not know how to document and/or has a patient on a program of care for a condition that is over 60 days old or more than 12 visits, the carrier will now ask for more records as they now believe they can get some money recovery from this doctor.

It is critical to understand the "philosophy" of Chiropractic Medicare, to deal with Medicare like a Chiropractor and "STOP" treating patients in regards to their symptoms.  Revisit your thinking when doing Medicare.  Evaluate your Medicare patients as a Chiropractor.  Nearly all your Medicare patients do not have new conditions and new diagnosis.  They have exacerbations in direct relation to chronic predisposed arthritic subluxations.

Hardly ever do you see a new condition with a senior patient.  That should spark your thinking.  Once you understand chiropractically how Medicare works, learn the correct way to "document", understanding the honest "diagnosis", you will find Medicare an excellent Chiropractic program.

With an understanding of the correct way to do Chiropractic Medicare, now you can use your energy in becoming Medicare Compliant by the end of 2012.

      

Spring 2012 Seminar Schedule:

*Thursday, June 21, 8:00 am - 12:00 pm at Comfort Inn & Suites, Mount Laurel, NJ

*Thursday, June 21, 5:00 pm - 9:00 pm at Holiday Inn, Saddle Brook, NJ

*Saturday, June 23, 8:00 am -12:00 pm at Holiday Inn Express University, Albany, NY

*Thursday, June 28, 8:30 am - 12:30 pm at Holiday Inn Express, Mishawaka, IN

  (4 hrs. Risk Management Continued Education - add $35.00 to registration)

  Have questions? Give Dr. Street a call today at (618) 395-3800.

Sent June 12^th, 2012

“ABN Option #2 - Covered and Non-Covered Service”

Albany, New York, Mount Laurel and Saddle Brook, New Jersey and Mishawaka, Indiana are upcoming Chiropractic Medicare Seminars for the month of June.  In those seminars I will cover the "Basics" Chiropractic Medicare information and review the steps on becoming Medicare Compliant.  If you have not attended one of our presentations, please call and register.  I promise you will receive information you will be happy to have… plus have fun.

ABN Option #2

For the Chiropractors that are "treating" patient symptoms, Option #2 on the ABN is dangerous.  Many Chiropractors "believe" when a patient has no symptoms, just call the Chiropractic adjustment "Wellness Care" or "Maintenance Care" and that way they "believe" they do not have to bill Medicare for the Chiropractic adjustment.

The patient signs Option #2 on the ABN and the doctor believe the adjustment is now a "non-covered service" in Medicare.  So not only does the doctor NOT bill Medicare for the Chiropractic adjustment. the doctor also collects from the patient at time of service for the Chiropractic adjustment, even though the doctor is a participating provider.

As a Participating Provider, your Federal Contract says that you can NEVER collect the 80% of the set Medicare fee for the adjustment at time of visit. You must ALWAYS accept assignment on a Medicare patient.  The Chiropractic adjustment is ALWAYS a covered service by Federal Law.  It may not be payable, however, by Federal Law, it is the only covered services for we Chiropractors.

Option #2 is for ONLY a non-covered service.  Simply, the Chiropractic adjustment must always be billed to the Medicare Carrier and Option #2 has nothing to do with a covered service. 

Remember: the fines are up to $10 thousand dollars per incident when not billing a covered service.

Sent June 18^th, 2012

“Audits, Appeals and Record Requests”

All Chiropractors and staff first must know the correct way to do Chiropractic Medicare.  When done correctly, your Medicare Carrier will recognize you are doing it correctly on your claim form and will stop asking for your records.

As far as I know, our Chiropractic Medicare Program is the only one presenting "documentation" by federal standards.  That information is entered in Item #19 on the initial claim, so the Medicare Carrier recognizes you have the "Documentation."  This information will cut most of the records requests.

The Appeals Process is fair; however, the first two steps of the Appeals Process (Request for Redetermination and Reconsideration) are still with the Medicare Carrier.  Due to the hassle and time frame dealing with Step 1 and Step 2, most Chiropractors either have done Chiropractic Medicare wrong or simply "give up"!

The third step in the Appeals Process (Request for Administrative Law Judge Hearing) is outside your carrier. If you have "documented by Federal Standards" you will be successful.

  Have questions? Give Dr. Street a call today at (618) 395-3800.