ICD-10 Migration and Episode Care

Chiropractic Medicare 2015

1.  ICD-10 Migration

2. Episode Care

1.  ICD-10 Migration

     On October 1, 2015 the ICD-9 Code sets used to report medical diagnosis and inpatient procedures will be replaced by ICD-10 code sets.  Those using certified software should be compatible with both ICD-9 and ICD-10. Your software company will provide tools to change over to ICD-10 and have the training for the provider to properly code.  If you have questions about your software being able to "Migrate to ICD-10" please call your software company TODAY.

     If you are not paperless, you may wish to print out the ICD-10 codes for your review.  It will print over 60 pages.  As you review, you will soon see very few of the ICD-10 codes will be used in your practice. Review the list and mark your codes.

     The problem for our profession is real. Somewhere around eleven thousand of the 60 thousand practicing Chiropractors became paperless and Medicare compliant.  For those not using certified software, be prepared for major delays in reimbursement by Medicare and insurance companies.  I strongly recommend having ALL your billing up-to-date prior to October 15th of this year.

2.  “Episode”

     Medicare carriers are now reviewing Chiropractic care by “Episode” units.  I have no problem with that. Our job in Medicare is NOT treating patient symptoms, but correcting vertebral subluxations.  As long as you practice like a Chiropractor in Medicare.....the fewer problems you will have. YOUR SUCCESS AND SECURITY IS UP TO YOU!    

     Be a Doctor of Chiropractic........Remember, always tell the truth!   

CERT, Audits, and Security Risk Analysis

Newsletter

February 18, 2015

CERT, Audits, and Security Risk Analysis

     Every Doctor of Chiropractic and Chiropractic Corporation having an NPI number received a package from your Medicare Carrier called “CERT & YOU.”  It contained magnetic stickers, a flyer and a DVD.  This information is specifically for we Chiropractors to reduce the CERT error rate by directly engaging and partnering with each doctor to prevent CERT errors.

     “Watch the DVD” and go to your Medicare Carrier website to review “Medicare Policy & Review”.  Take this information serious, review it with the knowledge that we will be access to random audits by not only CERT, but by CMS, your Medicare Carrier with pre and post audits.

     Presently many Chiropractic offices are requested to present their “Security Risk Analysis.”  Review your software for this information.  Your certified software will have all the questions available for you and your staff to complete.  It is basically pretty simple....it just needs to be done.

     The biggest problem with CERT, and other audits, is that most Chiropractors are not doing Medicare correctly, especially documenting the “Chiropractic Necessity of Care”.  If you have attended our presentation or purchased our Chiropractic Medicare DVD....take a moment, review the material given to you and start producing “documentation” as presented....(remember – SOAP Notes are not documentation!)  Those that have our information know what “Documentation” is....use it correctly every Medicare patient visit so when audited, you will be successful.

You Must Meet the Requirements for Core Measure #15

I need a Security Risk Analysis? What is that? I get calls from Chiropractors or their staff with this question every week. Here is the information and links to help you better understand Core Measure 15.

But first, from: http://www.healthit.gov/providers-professionals/certification-process-ehr-technologies

“The Office of the National Coordinator for Health Information Technology (ONC) Certification Program provides a defined process to ensure that Electronic Health Record (EHR) technologies meet the adopted standards and certification criteria to help providers and hospitals achieve Meaningful Use (MU) objectives and measures established by the Centers for Medicare and Medicaid Services (CMS).

Eligible professionals and eligible hospitals who seek to qualify for incentive payments under the Medicare and Medicaid EHR Incentive Programs are required to use certified EHR technology.”

Translation: The Certified Software you purchased is required to meet certain criteria in order to be a Certified Technology by the ONC. The job of the software is to help you meet all of the requirements. They are all set up basically the same and have training requirements, video tutorials, how-to documents, and support staff available to you. It is important and necessary to use not only the software but to use the training and support available to your office.

The Core Measure #15, also referred to as “Protect Electronic Heath Information”, or “Security and Risk Analysis”

This Core Measure has been wreaking havoc on Chiropractors. It isn’t a number to report found on your Dashboard. It’s a report or template that should be provided by your software company and completed in your office during the reporting period. A security risk analysis comprises the following parts: Risk Analysis, Risk Management, Sanction Policy, and Information Systems Activity Review. Think of it as an audit of your software and how you and your staff are protecting the fragile information contained therein. It should be easy to get these 4 templates or forms, run the audit, complete the forms, and file them in a safe place. The problem is most offices skip this step, and attest “YES” anyway. Later, when asked by CMS to provide their Risk Analysis they fail to provide and have to pay their incentive back.

The Measure states: “Conduct or review a security risk analysis in accordance with the requirements under 45 CFR 164.308(a)(1) and implement security updates as necessary and correct identified security deficiencies as part of its risk management process.”

Going further, below you will find better description of the 4 things you need:

(From: http://www.gpo.gov/fdsys/pkg/CFR-2003-title45-vol1/pdf/CFR-2003-title45-vol1-sec164-308.pdf)

164.308(a)(1)(i) Standard: Security Management Process. Implement policies and procedures to prevent, detect, contain, and correct security violations.
(ii) Implementation specifications:
(A) Risk analysis (Required) - Conduct an accurate and thorough assessment of the potential risks and vulnerabilities to the confidentiality, integrity, and availability of electronic protected health information held by the covered entity
(B) Risk management (Required) - Implement security measures sufficient to reduce risks and vulnerabilities to a reasonable and appropriate level to comply with 164.306(a). (Link found here: http://www.gpo.gov/fdsys/pkg/CFR-2010-title45-vol1/pdf/CFR-2010-title45-vol1-sec164-306.pdf)
(C) Sanction policy (Required) - Apply appropriate sanctions against workforce members who fail to comply with the security policies and procedures of the covered entity.
(D) Information system activity review (Required) - Implement procedures to regularly review records of information system activity, such as audit logs, access reports, and security incident tracking reports.

*****

More links regarding Core Measure #15. Some are full of long explanations, but still full of information.  

http://www.hitechanswers.net/meaningful-use-measure-and-hipaa/
http://www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/Downloads/SecurityRiskAssessment_FactSheet_Updated20131122.pdf
http://www.healthit.gov/sites/default/files/pdf/privacy/privacy-and-security-guide.pdf
http://www.hhs.gov/ocr/privacy/hipaa/administrative/securityrule/rafinalguidancepdf.pdf
http://www.youtube.com/watch?v=ml4okcBxN6c
http://www.youtube.com/watch?v=1fDvzznChhg

"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.

"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. 

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

****

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.

MAY Newsletters 2012

MAY Newsletters

(Sent out May 7th, 14th, 21st and 30^th)

Chiropractic Medicare

Sent May 7^th, 2012

"Some Medicare Carriers have limited Chiropractic!"

Dear Doctors and Staff,

The Medicare Carrier of Tennessee has posted their draft indicating "Chiropractic limitations" as 25 chiropractic visits per year.  The Medicare Carrier in "New Jersey" posted guidelines limiting chiropractic visits to 30 per year.  I am sure other carriers have created "in house" chiropractic limits that I am not aware of presently.

However, to my knowledge, CMS has issued NO limits on Chiropractic Care as long as the adjustments are medically necessary.  That simply means the state Medicare Carriers have posted limitation on Chiropractic illegally.  Who's to stop them?  CMS does not seem to care that the Medicare Carriers are breaching Federal law by these limitations.

In each state, when the Medicare Carrier creates Chiropractic limitations, the State Chiropractic Associations and Societies should file complaints with their Congressmen and Senators to get it stopped. IT MUST BE STOPPED NOW!!!

Even if there WERE TO BE limitations of 25 or 30 visits per year, we still must know the correct way to do Medicare and we still must become compliant in Medicare by the end of 2012.  Because the error rate on Chiropractic billing and documentation has been in the 60% to 99%, those reports were issued by the Inspector General to Congress.  If we are to stay in Medicare and also in the new insurance program (Obama Care), we have to prove we are smart enough to be part of the program.

Most Chiropractors and staff believe they are doing Medicare correctly, however, statistics indicate most are not.  If you think you are doing Medicare correctly, however, not sure, give me a call and we will talk about it! With 34 years of Chiropractic Medicare experience, those that have learned to do Medicare correctly are having very little trouble with getting paid and are also being successful with audits.

My recommendation is simple....beg, borrow, steal or purchase "The Basics" Chiropractic Medicare DVD and booklet so you know how Medicare works and so you know how to "document" the Chiropractic necessity of care.

If you are going to stay in practice after 2013, you also must become compliant in Medicare.  You may wish to consider the Medicare Compliance book and CD. It's ready to start you and your staff on the way to becoming compliant.  Sooner or later you have to do this. May as well make it sooner and save the trouble and heartache.

Consider "The Basics" Chiropractic Medicare DVD and booklet.  And since we also must become Medicare compliant by the end of 2012, consider our bundle which includes the Chiropractic Medicare Compliance CD and booklet.  Protect yourself....it's up to you to do it correctly. Don't fool around or procrastinate!!!!  Get this information TODAY!!

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

Post Script NOTE: (Illinois Chiropractors) WPS has lost it's Medicare Carrier contract. The new Medicare Carrier in Illinois is CIGNA. Each will be notified.

      

Spring 2012 Seminar Schedule:

*Thursday, May 17, 1:00 pm - 5:00 pm at Hampton Inn-Downtown, Indianapolis, IN

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

*Thursday, May 24, 8:30 am - 12:30 pm at King Oscar Hotel, Pacific, WA

*Thursday, May 24, 6:00 pm - 10:00 pm at Staybridge Suites, Mukilteo, WA

*Saturday, May 26, 8:30 am - 12:30 pm at Quality Inn Oakwood, Spokane, WA

*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)

Sent May 14^th, 2012

Dear Doctors and Staff,

This week, Thursday, we will be in Indianapolis, IN, 1:00 pm to 5:00 pm for a four hour Continued Education credited Chiropractic Medicare presentation.  Those attending will receive 4 hours CE credits certificate, examples in our Seminar booklet and Chiropractic Compliance Guidelines booklet.

Next week we will be in the State of Washington at Pacific and Everett on May 24th and Spokane on May 26th.  All three are sponsored by South King County Chiropractic Society and WCA with 4 CE credits.

These presentations are important.  Those attending get the idea of the correct way to do Chiropractic Medicare.  They return to their offices, correct errors, implement what they learn, and are successful with Medicare....plus sleeping good at night.

To my knowledge, I have not yet met the Chiropractor or staff that was already aware of the "documentation" used successfully in Medicare before attending our presentation or studying or DVD.  So when my fellow Chiropractors tell me they are doing Chiropractic Medicare correctly and talk about their S.O.A.P. note documentation....it becomes obvious there is a problem!

After last weeks Medicare article, we received several emails indicating several other state Medicare Carriers have placed limitations on the chiropractic adjustments. That guideline change limiting chiropractic coverage has not officially been adopted by CMS.

The biggest problem is that Chiropractors believe they are doing Medicare right because they are getting paid.  (As long as you bill a "clean claim" most Medicare Carriers pay that claim and audit later by request of patient records.) So now many chiropractors are not interested until they have a Medicare audit and fail. (Remember...the Chiropractic Medicare error rate is 67% to 97% of ALL claims.) Now the STAFF is under pressure to make thing happen in Medicare since claims are not being paid and the office has to send patient records to the carrier.

Also, filed claims are denied by the carrier.  Even if the claim is billed correctly...some are denied, even first visit.  The appeals process should be used.  However, the majority of our profession has no idea about the five levels of Appeal and they give up after the first one or two levels are denied by the carrier.

Procrastination is dangerous when dealing with a federal program.  You must do it correctly or you either pay back money or lose the program.

Sent May 21^st, 2012

"Getting It Right!"

Dear Doctors and Staff,

We are very happy to receive reports back from our fellow Chiropractors in regards to the success with audits and reviews.  Those Chiropractors and Staff that have our information, by either attending seminars or the purchase of our DVD and booklet, are very successful.  The reason being they are doing Medicare correctly.

Medicare carriers in each state are implementing visit restrictions for chiropractic care. The Federal Law indicates there are NO limits in Medicare for the chiropractic adjustment as long as it is Medically necessary. Since very few chiropractors know the correct way to "Document the Chiropractic Necessity of Care", we are now facing those limits by default. Nobody is challenging the Medicare carriers and they are getting away with unlawful limits.

However, sometimes even if you do Medicare correctly you may receive denials from your Medicare Carrier. When that happens, review your claims for any errors and file an appeal.

Remember, the first two (2) steps of the appeals process is still with your Medicare Carrier. The third step requires a review by an administrative law judge OUTSIDE your Medicare Carrier. Nearly always you will be successful... especially if you have our material since our documentation has been approved by the administrative law judges.

Sent May 30^th, 2012

"Do It Correctly - or Lose!"

Dear Doctors and Staff,

The Medicare Carriers that have placed limits on the number of Chiropractic adjustments per patient per year have demanded we Chiropractors do it right....or we lose.

There are NO limits for the Chiropractic adjustments in the Medicare program.  However, each Medicare Carrier may establish in-house limits that we can exceed if we do Chiropractic Medicare correctly and challenge the carrier through the Appeals Process.

If you are actually doing Chiropractic Medicare correctly and wade through the Appeals Process to the Administrative Law Judge Appeals level, you should win each challenge.

(The problem with the Appeals process is that the first two stages are still with the Medicare carrier and usually denied. Most chiropractors give up before it goes to the third step with the Administrative Law Judge.)  If you are NOT doing Medicare correctly, you will lose in the Appeals, even through the Administrative Law Judge (ALJ).

If you still believe your S.O.A.P. notes are “documentation” in Medicare, then you will learn the hard way which will cost you some big bucks.

I strongly suggest that you consider three important items we have to offer:

1.      "The Basics" Chiropractic Medicare DVD and booklet.  This contains everything you and your staff must know to do Medicare correctly.

2.      The Audit and Appeals Process DVD and booklet.  If you are going to know how to defend yourself in an audit, this item walks you through the Appeals Process so you don't "give up" before you win.

  3. Chiropractic Medicare Compliance CD and booklet.  We all must become compliant by the end of 2012.  We have it completed.  It is ready for you to implement it into your practice.  The faster the better to become compliant.

A couple of notes from fellow Chiropractors:

May 14, 2012

Hey Doc, 

Just wanted to let you know that I won my ALJ decision for my audits going back to end of 2010 and early 2011!  You said I would, and I must say, I had my doubts the way things are going here in NY.  They found 100% in my favor.  Thanks for your help throughout the process.  I truly appreciate it.

All the best,

Ed Casper, DC

May 22, 2012

To Whom It May Concern:

It was a great blessing running into Dr. Street 7 years ago.

He was like a prophet with his predictions about where Medicare and Chiropractic would go.

We have followed his recommendations to a T.  It is nice for patients to know what their financial responsibility is and which services are the responsibilities of Medicare.

His procedures are efficient and ethical with no "gimmicks".

Outside of cumbersome paperwork, Medicare audits go through like a breeze by following Dr. Street's procedures.

If you are a Chiropractor who is a Medicare provider, you cannot afford to not attend this seminar.

Sincerely,

Dr. Joseph Clauss

Dr. Carolyn Clauss

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

"Everything Has To Match!"

Newsletter

April 30, 2012

Chiropractic Medicare

"Everything Has To Match!"

Dear Doctors and Staff,

The phone is ringing more and more from fellow Chiropractors dealing with audits and requests for records.  Many times that phone call happens BEFORE they mail their records. However, many times it is after they have sent records and now the carrier is requesting money back.

If that phone call I get is before they mailed records, or better yet, prior to the carrier requesting records, we can review and help you correct errors.

NO, I am not a hired consultant and NO, I do not get paid for my recommendations.

My only request is that the doctor consider our "Chiropractic Medicare DVD and booklet" and “Chiropractic Medicare Compliance CD and booklet” so they learn the correct way to do Medicare and are compliant by the end of this year!

Things must match on the claim:

 

1.      If item #14 Date of Current is over 60 days, you have told the Medicare Carrier this is a "Chronic Condition” therefore, this claim will be pulled for review.

2.      If your diagnosis does not "support" the adjustments billed, this claim will be pulled for review.

3.      If your number of visits does not match your diagnosis and/or Item #14 Dates of Current, this claim will be pulled for review.

4.      If you are not collecting Exacerbation Data and documenting that data on a "Document", then you have not "documented the necessity of care”. This claim will fail an audit.

5.      If item #19 does not contain the date of x-ray or indicate a P.A.R.T. form was completed for that visit, this claim will be pulled for review.

6.      If item #19 does not contain the terminology indicating you have "documentation", this claim will be pulled for review.

7.      If the information you send to the carrier about a service does not have "Documentation" and a "Treatment Plan", you lose and they will ask for more records. (S.O.A.P. notes are NOT documentation.)

Protect yourself! It's up to you to do it correctly. Don't fool around or procrastinate! Get informed TODAY!!

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

Spring 2012 Seminar Schedule:

*Thursday, May 17, 1:00 pm - 5:00 pm at Hampton Inn-Downtown, Indianapolis, IN

*Thursday, May 24, 8:30 am - 12:30 pm at King Oscar Hotel, Pacific, WA

*Thursday, May 24, 6:00 pm - 10:00 pm at Staybridge Suites, Mukilteo, WA

*Saturday, May 26, 8:30 am - 12:30 pm at Quality Inn Oakwood, Spokane, WA

To Register Call:  (618) 395-3800

Treatment Plan in Chiropratic Medicare

Newsletter

April 23, 2012

Chiropractic Medicare

"Treatment Plan"

Dear Doctors and Staff,

I am certain everybody has about had it with Medicare and the constant threat of audits.  However, think about this the Chiropractors in Kentucky had a 99.7% fail rate on their last audit.  Southern California fail rate was 77%.

The bottom line, we either learn how to do Chiropractic Medicare correctly or we are going to lose big bucks with Medicare audits and then lose the whole Chiropractic Medicare Program.  With such huge error rates, we have already lost from "No limits in Medicare for the Chiropractic adjustment" to a "25 Chiropractic Medicare limit per patient per year.  I project if we do not improve our ability to do Chiropractic Medicare correctly, we will be out of the Medicare program.  (That also means our inclusion in Obama Care will be challenged.)

The 99.7% fail rate in Kentucky and "across the rest of the country", is because none or poor "treatment plans".  There must "always" be a "treatment plan", whether acute, chronic or an acute exacerbation on a chronic condition.

What goes into a "treatment plan"? 

Here it is: both short and long term goals, your patient protocol as to what you will adjust and how and on what frequency, any contraindications and/or complicating conditions.  What, where, who, time of any modalities/therapies, home care instructions, lifestyle modifications, outcome assessment and re-examinations.

Remember...you have to know the correct way to do Chiropractic Medicare and you must become "Compliant" in Medicare by producing "documents" in seven (7) "specific" areas.

Don't fool around or procrastinate!!!!  Get informed TODAY!!

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

Spring 2012 Seminar Schedule:

*Thursday, May 24, 8:30 am - 12:30 pm at King Oscar Hotel, Pacific, WA

*Thursday, May 24, 6:00 pm - 10:00 pm at Staybridge Suites, Mukilteo, WA

*Saturday, May 26, 8:30 am - 12:30 pm at Quality Inn Oakwood, Spokane, WA

To Register Call:  (618) 395-3800

"Areas of GREAT Concern" (Requests for Patient Records, Denials, Redetermination and Reconsideration aka The Appeal Process)

Newsletter

April 17, 2012

Chiropractic Medicare

"Areas of GREAT Concern"

Dear Doctors and Staff,

A huge area of concern is the Error Rate established by the Medicare Carriers across the United States.  67% of all claims billed to Medicare Carriers contained errors.  Some states the error rate is worse.  In Southern California the error rate is 77%!

After speaking with hundreds of DC's and their staff by phone I can assert that these people are not dumb.  The Inspector General, with "special" reports to our Senators and Congressmen, has given Congress an impression that Chiropractors are not too bright.

The First Problem is the incentive to learn. When (for example) the reimbursement for a 98940 is $24.56, the incentive to study and know all the Medicare Federal Guidelines seem pretty small.  Since about 96% of all Chiropractors in the U. S. are participating providers, either you don't get paid, or if you do get paid, there is always the fear of a Post-payment Audit and you end up paying everything back to the carrier.

To make the problem worse, more and more Medicare Carriers are simply denying all claims, first patient visit or 10th patient visit, whatever.  They know most Chiropractors do not know what to do next and the carrier wins.  A few Chiropractors who know a little of the Audit and Appeals process request a “Redetermination”.  This is performed by an individual at the Medicare Carrier not involved with the original determination.

At no surprise, usually the redetermination agrees with the original denial.  Usually 45 days have passed and the second denial is received.  Now the Chiropractor may request a “Reconsideration".  This is done by a "Qualified Independent Contractor" similar to first level of appeal.

Another 45 days pass and here comes another denial.  No surprise because it's from the same Medicare Carrier.  By now the Chiropractor has wasted 80 plus days, messed with patient records two or three times, all for $24.56.  Most DC's toss up their hands and give up.

If you will take those reviews and appeals to the next step and having done Medicare correctly, you have a great chance of winning.  When your appeal finally gets to the Administrate Law Judge (away from your Medicare carrier) you will most always win.  Just be sure you are doing Chiropractic Medicare correctly.

The Second Problem:  In several states like New York, New Jersey, Tennessee, California, Wyoming, etc., the Medicare Carriers consistently ask for all patient records that are billed by a Chiropractor.  Some states back log of patient records is unbelievable, however, they continually keep asking for records, and until they are reviewed, not one claim is reimbursed.

There seems to be some loss of government control with these specific carriers.  I recommend the State Chiropractic Associations in these states contact their Congressmen and Senators and file formal complaints against this action as quickly as possible. It is very possible the system is being abused by the Medicare carriers.

Most Important:  You have to know how to do Medicare correctly and become Compliant!

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

Spring 2012 Seminar Schedule:

*Thursday, April 19, 1:00 pm - 5:00 pm at the Chariot Hotel - Louisville, KY

*Thursday, May 24, 8:30 am - 12:30 pm at King Oscar Hotel, Pacific, WA

*Thursday, May 24, 6:00 pm - 10:00 pm at Staybridge Suites, Mukilteo, WA

*Saturday, May 26, 8:30 am - 12:30 pm at Quality Inn Oakwood, Spokane, WA

To Register Call:  (618) 395-3800

"Think Like a Chiropractor"

Newsletter

April 9, 2012

Chiropractic Medicare

"Think Like a Chiropractor"

Dear Doctors and staff,

Many times, when speaking of Medicare, HIPAA, or becoming "compliant" in Medicare, it comes off as a "negative" and a "downer". 

Most people have no idea the Medicare Chiropractic section was written by Chiropractors Dr. Bill Day of Washington, Dr. Bob Hulsebus of Illinois, etc. 

“If we do Chiropractic Medicare as Chiropractors instead of acting like another health discipline, as your Medicare Carriers want you to be, you will have little to no problem with Medicare.”

The Chiropractic Medicare guidelines do not say we are reimbursed for "treating" our patient’s symptoms. It says we are only paid in Medicare for “correcting a vertebral subluxation”.

The vertebral subluxation is the only "covered service" in Medicare for Chiropractors.  The vertebral subluxation is "always" a covered service in Medicare; however, it may not be a payable service if we cannot document the Chiropractic necessity of care. It is always the covered service which is the reason we must bill all Chiropractic adjustments to correct a vertebral subluxation.  For the patient to mark Option #2 on the ABN, calling it maintenance care when the Chiropractor corrects a vertebral subluxation, is very questionable and dangerous.  The adjustment to correct a vertebral subluxation is the only covered service in Medicare and must be billed within one year.

For the Chiropractor to call the Chiropractic adjustment to correct a vertebral subluxation "maintenance care," patient signs Option 2 on the ABN, creates several problems.

1. The patient pays a monthly premium in Medicare for the healthcare that will not reimburse the patient if the Chiropractor does not bill or bill correctly.  The patient is cheated.
2. When a Chiropractor provides a covered service (98940, 98941 or 98942) in Medicare, they are required to bill Medicare within one year.  You may call it Maintenance Care, however, if you corrected a vertebral subluxation that is a "covered service" and should be billed and documented for Medicare reimbursement.
3. Just because a patient has NO obvious symptoms does not make this "maintenance care."  The patient may be on seven (7) prescription drugs and feel no symptoms.
4. When a patient has a "vertebral subluxation", they must have a related "Neuronal Component" or it is not a Subluxation.
1. Example...Subluxation of T6 with the neuronal trajectory of T6 spinal nerve to the stomach altering the function of the stomach. They are probably on three prescription drugs for a stomach problem   from their MD.

Think and be a Chiropractor in Medicare.  That is how the Medicare Program was developed in 1973.

Do you know the importance of learning the correct way to do Medicare by federal standards and becoming Medicare Compliant?

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

Spring 2012 Seminar Schedule:

*Thursday, April 19, 1:00 pm - 5:00 pm at the Chariot Hotel - Louisville, KY

*Thursday, May 24, 8:30 am - 12:30 pm at King Oscar Hotel, Pacific, WA

*Thursday, May 24, 6:00 pm - 10:00 pm at Staybridge Suites, Mukilteo, WA

To Register Call:  (618) 395-3800

Audits and Compliance in Medicare "It All Fits Together!"

Newsletter

April 2, 2012

Chiropractic Medicare

"It All Fits Together!"

Dear Doctors and Staff,

It all fits together....however....first things first!

I have the privilege of speaking to many Chiropractors and Chiropractic staff daily.  We do have Chiropractic Medicare problems in the Chiropractic field of practitioners.

It is obvious the Inspector General is close to correct, that of every 100 claims filed by Chiropractors, 67 have errors!  That is not even the worst part.  All "clean" claims are automatically paid.  Then the carrier hires a special agency to do audits to get the money back.

Some states, New Jersey, New York, California and Nevada, audit nearly every claim, asking for hundreds of patients notes.  Most all are denied with first Review Determination.  When the Chiropractor goes to the second Level of Review Reconsideration (still with the Medicare Carrier) it nearly always is denied again.  Most DC's give up at this point and lose.

We cannot afford to not be paid or have to send money back to the Medicare Carriers.  We have to know the correct way to do Chiropractic Medicare.  I suggest considering our "The Basics" Chiropractic Medicare DVD and booklet.  It covers everything we Chiropractors and staff must know when doing Chiropractic Medicare.

Becoming compliant in Medicare is something totally different.  The Federal Government now has a mandated program set up to stop fraud and abuse in the Medicare program.  Having prepared the Chiropractic Compliance program....it will stop fraud and abuse.

We Chiropractors are required to implement this program by the end of 2012. (9 months to go!)  If you decide to put it off or not do this program, by 2014 - 2015 you will have major difficulty being in Chiropractic practice. Having the Compliance Program already completed for you is a giant step forward.  All you have to do is place your office data on all the documents and you are well on your way to Chiropractic Medicare Compliance.

HIPAA and OSHA are two more areas that chiropractors and staff must be proficient. I will discuss those next week.

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

Spring 2012 Seminar Schedule:

*Thursday, April 19, 1:00 pm - 5:00 pm at the Chariot Hotel - Louisville, KY

*Thursday, May 24, 8:30 am - 12:30 pm at King Oscar Hotel, Auburn, WA

*Thursday, May 24, 6:00 pm - 10:00 pm at Staybridge Suites, Mukilteo, WA

*Saturday, May 26, 8:30 am - 12:30 pm at Quality Inn Oakwood, Spokane, WA

To Register Call:  (618) 395-3800

Step 7 of the 7 Mandated Steps "Responding to Detected Offenses, Developing Corrective Action Initiatives, and Reporting to Government Authorities"

Newsletter

March 26, 2012

Chiropractic Medicare

"Becoming Compliant"

Step 7 of the 7 Mandated Steps

Dear Doctors and staff,

Our future is not merely something that happens to us, but something that we participate in creating.  If we do this constantly, we can create an organized environment that works for both Chiropractors and Medicare.

I am finding the majority of Chiropractors have no idea, as of yet, their mandated responsibility of becoming Medicare compliant by the end of 2012.  Some DC's have stuck their heads in the sand hoping it all will go away.  However, about 10% to 20% of my fellow Chiropractors are collecting information and have made the move to become compliant.  Those are the one's that will be in a strong Chiropractic business in 2014.

You first must know the correct way to do Chiropractic Medicare, then, you must know how to protect personal health information you have collected from your patients, and last, you must become compliant in Medicare.

   

Medicare Compliance Step # 7: Responding to Detected Offenses, Developing Corrective Action Initiatives, and Reporting to Government Authorities

Our guidebook has complete written guidelines in reference to responding to detected offenses, developing corrective action and reporting to government authorities.  It has written policy about Internal Investigations with 30 categories already prepared for your office.  It contains a Case File Report, Log of Non-Compliance form, Post-Audit Monitoring Report, Release Statement, Progressive Discipline Policy, Discipline Documentation Form, Human Resources Department, Guidelines for Interaction between Compliance Department and Internal Audit Department, Exit Interview Questionnaire, and How to Report Medicare Fraud.  It's already completed for you and your staff.

Becoming compliant in Medicare can be fairly easy or so difficult many will not even try.  That is up to you.  We have put all the difficult stuff together for you.  Now you must decide. Are you going to become compliant?  (If not, you won't have much of a practice in 2013-2014.)  Yes, you will attempt to become Compliant and must be ready by the end of this year.

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

Spring 2012 Seminar Schedule:

*Thursday, March 29, 1:00 pm - 5:00 pm at Urbana Country Club, Urbana, IL

*Thursday, April 19, 1:00 pm - 5:00 pm at the Chariot Hotel - Louisville, KY

*Thursday, May 24, 8:30 am - 12:30 pm at King Oscar Hotel, Auburn, WA

*Thursday, May 24, 6:00 pm - 10:00 pm at Staybridge Suites, Mukilteo, WA

*Saturday, May 26, 8:30 am - 12:30 pm at Quality Inn Oakwood, Spokane, WA

To Register Call:  (618) 395-3800

Step 6 of the 7 Mandated Steps "Enforcement through Publicized Disciplinary Guide-lines and Policies Dealing with Ineligible Persons"

Newsletter

March 19, 2012

Chiropractic Medicare

"Medicare Compliance"

Step 6 of the 7 Mandated Steps

Dear Doctors and Staff,

Seems like a slow process, however, several Chiropractors and their staff are realizing "becoming compliant in Medicare" is different than learning the correct way to do Medicare.  Even though Chiropractors have a chiropractic Medicare billing error rate of 67%, that has very little to do with becoming "compliant." The error rate of 67% simply means the majority of Chiropractors and their staff does not know the correct way to do Medicare. Becoming compliant in Medicare is when you have implemented the seven (7) mandatory steps in your practice to stop fraud and Medicare abuse.  Over the past several weeks, I have been talking about each of the seven mandatory steps.

Medicare Compliance Step # 6

Enforcement through Publicized Disciplinary Guide-lines and Policies Dealing with Ineligible Persons:

You must have written policy for your practice that apply appropriate discipline sanctions on those officers, employees, staff, etc., who fail to comply with applicable statutory Medicare requirements and with the contractor's written standards of conduct.  You shall have a list of policies which include specific sanctions.  You shall have factors considered before disciplinary actions are imposed.  You shall have a hand written guideline in regards to Progressive Discipline along with the elements of a progressive discipline system.

You shall also have written policies and guidelines in regards to the employment conduct with ineligible persons.  Your guidelines should include how to conduct an employee background check along with an employee application and screening that answers all the necessary information in regards to an employee application.

The purpose of these seven (7) steps in Chiropractic Medicare Compliance is to stop fraud, abuse and errors.  As you will see....the program is extremely effective.  Next week we will cover item # 7, "Responding to Detected Offenses, Developing Corrective Action Initiatives and Reporting to Government Authorities" as mandated by the government.

Becoming compliant in Medicare can be fairly easy or so difficult many will not even try.  That is up to you.  We have put all the difficult stuff together for you.  Now you must decide if you are going to become compliant.

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

Spring 2012 Seminar Schedule:

*Thursday, March 22, 1:00 pm - 5:00 pm at Staybridge Suites - St. Louis, MO

*Thursday, March 29, 1:00 pm - 5:00 pm at Urbana Country Club, Urbana, IL

*Thursday, April 19, 1:00 pm - 5:00 pm at the Chariot Hotel - Louisville, KY

*Thursday, May 24, 8:30 am - 12:30 pm at King Oscar Hotel, Auburn, WA

*Thursday, May 24, 6:00 pm - 10:00 pm at Staybridge Suites, Mukilteo, WA

To Register Call:  (618) 395-3800