Seminars in Washington and Oregon

Date: Saturday, November 4, 2017

Time: 8:30 AM - 12:30 PM

Location: Portland, Oregon

Location address:

 Radisson Hotel Portland Airport

 6233 NE 78th CT

 Portland, OR 97218

Hotel phone: (503) 251-2000 for direction purposes only

To register or for questions please call: (618) 395-3162

Date: Thursday, November 2, 2017

Time: 8:30 AM - 12:30 PM

Location: Pacific, Washington

Location address:

 Quality Inn & Suites

 415 Ellingson Road

 Pacific, WA 98047

Hotel phone: (253) 288-1916 for direction purposes only

To register or for questions please call: (618) 395-3162

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.

1. Back to the Basics 2. History Book

Newsletter
May 6, 2013
Chiropractic Medicare
1. "Back to the Basics."
2. New Chiropractic History Book Introduced.
Knowing the error rate for we Chiropractors is at 72.9% as determined by CERT....knowing that they believe they have over paid we Chiropractors improper payments....somebody will be catching audits for money recovery! CERT says that the primary reason for the improper payment is "insufficient medical record documentation".

You may believe this has nothing to do with you since all of your claims have been paid. However, the 72.9% error rate is on claims that have been paid....improperly. If you believe S.O.A.P. notes is the documentation they are talking about...that’s a mistake! Documentation is not S.O.A.P. notes...it’s a document. That is why it is called documentation. That is the exact information I have been attempting to share with my fellow Chiropractors for the past 34 years.

1. The Basics in Medicare: You must prove a subluxation, x-rays each year or a P.A.R.T. form each visit. Item #14 must be less than 60 days old. Diagnosis must support the care rendered . S.O.A.P. notes in a S.O.A.P. note format. You must have "documentation" in the way of a "document" to prove chiropractic necessity of care. S.O.A.P. notes must indicate and support the CPT Code you billed.

2. NEW CHIROPRACTIC HISTORY BOOK INTRODUCTION: D. D. Palmer & B. J. Palmer started producing "The Chiropractor" booklets in December 1904. "The Chiropractor" were produced and printed each month for four years. We have made those available in two large volumes. They come with Certificate of authenticity of first copies. For those interested in Chiropractic History....these are not available anywhere else. We have a limited number available so please email or call if you are interested.

Newsletter ~ Two Questions

Newsletter
May 3, 2013
Chiropractic Medicare
#1. Who’s going to catch the audits?
#2. Mandatory Payment Reductions.

#1. Catching Audits..............

I have presented, time and time again, information in regards to Chiropractors becoming compliant in Medicare. And yet, only about one third have followed the Federal Mandate and Attested.

So....I shall say it again! Do you want to be in Chiropractic practice after 2016? If you don’t......just don’t do anything. If you do, and have not proceeded to becoming compliant, you are in your "Last Window of Opportunity". It’s over prior to 90 days to the end of the year!!

If you believe you do not have to become compliant, you are wrong! Both Medicare and Obama care require your compliance. Remember....it is against federal law to see a Medicare patient if you are not qualified.

AUDITS: So who’s going to catch the audits? Remember....72.9% of all Chiropractic claims have errors and we Chiropractors are being improperly paid...there will be audits.

Do you think the Chiropractor who has followed the Federal Guidelines, become Medicare Compliant using certified software, has attested, and has records readily available for review...or...the Chiropractor that has not become compliant, is not using certified software and not attested as to becoming Medicare compliant will be audited? The answer is not difficult! You begin with a certified software.

Questions? Give me a call! Don’t procrastinate!! This is important for your future in Chiropractic!

#2. Mandatory Payment Reductions...........

The Budget Central Act of 2011 requires, among other things, mandatory across-the-board reductions in Federal Spending, also known as Sequestration. The American Taxpayer Relief Act of 2012 postponed sequestration for 2 months. The order was set for March 1, 2012. In general, Medicare fees for service claims with dates of service on or after April 1, 2013, will incur a 2 percent reduction in Medicare payment.

Even though beneficiary payments for deductibles and coinsurances are not subject to the 2 percent payment reduction, Medicare payments to beneficiaries for unassigned claims are subject to the 2 percent reduction.

Have questions in regards to doing Chiropractic Medicare correctly, or becoming Medicare Compliant? Give me a call at (618) 395-3800.
Learn the correct way to "Document The Chiropractic Necessity of Care."

"Medicare Learning Network" (72.9% Chiropractic Medicare Fail Rate)

Newsletter

April 30, 2013

Chiropractic Medicare

"Medicare Learning Network"

(72.9% Chiropractic Medicare Fail Rate)

Well....we Chiropractors made the Medicare Quarterly Provider Compliance Newsletter again! (Volume 3, Issue 3 – April 2013). The very first report is Comprehensive Error Rate Testing (CERT) Special Study: Provider Types Affected: Physicians and Chiropractors.

Problem description:

The majority of chiropractic services claims errors in this review were the result of insufficient documentation. Note that the Medicare Fee-for-Service 2011 Improper Payment Rate Report’s finding that insufficient medical record documentation was the most common reason (72.9%) for improper chiropractic payment. (See "The Supplementary Appendices for the Medicare Fee-for-Service 2011 Improper Payment Rate Report," released on November 2, 2012 at http://www.cms.gov/research-Statistics-Data-and-Systems/Monitoring-Programs/CERT-Reports-Items/Nov2011Appendix.html on the CMS website.)

This type of error occurs when the medical records do not contain enough information for the reviewer to make a decision about medical necessity for the item or service furnished. Some common reasons for insufficient documentation errors were:

• The documentation submitted did not adequately describe the service defined by the billed CPT code, Healthcare Common Procedure Coding System (HCPCS) code, or HCPCS modifier;
• The documentation did not include the Date of Service (DOS) or the beneficiary’s name;
• The was no treatment plan documented to support a plan of care;
• The signature was illegible.

Other errors in this special study were categorized as medical necessity errors. These errors occur when the medical records contain sufficient documentation for the reviewer to determine that the services billed were not medically necessary based upon Medicare coverage policies.

A common reason for medical necessity errors was that the submitted medical records did not support the need for the service based on the Medicare National Coverage Determination (NCDs) and Local Coverage Determinations (LCDs). The rest of the medical necessity errors were due to claims in which the beneficiary symptoms were not related to the spinal regions manipulated.

Example: Mr. Jones’ medical record shows that he had an injury that led to a subluxation of the spine with acute back pain. However, as required by the chiropractic services LCD, the precise level of the subluxation was not specified by the Chiropractor. This claim was scored as an improper payment due to an insufficient documentation error.

Let’s Get Back to the Basics! The statistics indicate 72 out of every 100 claims filed were paid improperly. If you are going to stay in practice and do Medicare and Obama Care, you simply have to do it correctly!!

Recommendation – Have questions in regards to doing Chiropractic Medicare correctly, or becoming Medicare Compliant? Give me a call at (618) 395-3800. Learn the correct way to "Document The Chiropractic Necessity of Care"!

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

  ****

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

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.

Step 1 of the 7 Mandated Steps to Becoming Medicare Compliant

Newsletter

February 13, 2012

Chiropractic Medicare

Step 1 of the 7 Mandated Steps

Dear Doctors and Staff,

With the negative reports from the office of the Inspector General in regards to the poor track record of Chiropractors "documenting" the Chiropractic necessity of care along with the high rate in billing Medicare claims, we now find ourselves having to deal with a "mandatory" Medicare Compliance Program.

To stop errors, fraud and abuse in Medicare, Chiropractors and staff are requested to begin the Medicare Compliance Program.  A step by step procedure with time lines for compliance and information regarding Electronic Health Records Incentive Program.

If you choose not to become Medicare Compliant, by the year 2014 you probably will not have any Medicare patients and will lose a large number of Insurance Company privileges.

Centers for Medicare and Medicaid Services are preparing to implement the combination of HIPAA, protecting personal health information, along with addressing the high error rates, fraud and abuse in Medicare.  In doing so, each provider is required to bill electronically using ICD-10 codes uploaded onto a server clearinghouse also compliant using 5010 software.

As you proceed through this process, keep aware of the time lines and testing necessary to get to the next step.  Consider the incentive to be successful in both financial and protective of you and your patient's personal health information.

Step 1 of the 7 Mandated Steps:

a.       Written Policies and Procedures.

b.      Developing a written Standards of Conduct.

c.       Written Duties and Responsibilities of Management by (Owner/Doctor).

d.      Compliance Officer, Essential Duties.

e.       Compliance Committee and Duties.

f.        Retention of Records and Information Systems, Policy, Information,   

                                                               i.      General Guidelines.

g.       Compliance Element Policy, Meeting and Managers Annual Performance

                                                               i.      Evaluation.

The GOOD NEWS is we have this all completed in our Chiropractic Medicare Compliance Book and CD. The CD contains all the policies, procedures, detailed compliance training, reporting systems, disciplinary guidelines and policies, corrective action and self-audit procedures.  Our Medicare Compliance CD is in both Publisher and Word docs, ready for your staff to download, review and personalize for your Medicare Compliance.

If you have questions, please give me a call 618-395-3162. ~Dr. Street

Three Important Areas

Newsletter
February 8, 2012
Chiropractic Medicare
Three Important Areas We ALL MUST become Proficient In!

Dear Doctors and Staff,

This is the year for Chiropractors in Medicare.  Last year the Inspector General indicated that out of 100 claims filed to Medicare by Chiropractors, 67 had errors.  They believe they have overpaid Chiropractors by millions. With that in mind, nearly every Chiropractor filing Medicare claims will be audited in 2012.

There are three key areas in which we must be prepared:

First, we must know the correct way to provide great Chiropractic care to our seniors and document by federal standards. You must know the correct way to do Chiropractic Medicare!!! If you don't know the correct way to do Medicare an audit will be devastating.

The second area of our concern is HIPAA (i.e. knowing how to protect personal Health Information in your office, developing your in-house HIPAA policies, procedures and training.)

The third area of concern is becoming Medicare Compliant. By the end of 2012 each and every Chiropractic office must be aware and prepared for the seven (7) areas of compliance set by the Federal Government.

We offer many helpful items to help with these areas to help you get prepared. If you have questions, comments, concerns about Chiropractic Medicare, please give me a call at 618-395-3800.

Warmest regards,
Dr. Street

Chiropractic Audits Gone Wild!

Chiropractic Medicare
Audits...Audits...Audits!

My phone calls are increasing especially from New York, California, Nevada, and now Alabama!

Palmetto Medicare Carrier in California and Nevada broke the ice and requested thousands of Chiropractic records as both pre-payment and post payments audits. Then, the New York Medicare Carrier went wild with requesting records on every patient.

Now the Alabama Medicare Carrier is following suit with audit after audit on Chiropractors, requesting records/documentation for a specific period of time and any portion of the preceding 6 months prior. 

These audits, first, eat up the small profits we get in Medicare. Secondly, they stress both the doctor and the staff effecting the quality of Chiropractic care delivered.  The major problem is that most Chiropractors lose some or all of their audit because of mistakes or lack of knowledge in Medicare procedures. 

Speaking with hundreds of Chiropractors dealing with audits, they all have made the following errors that cost them big time:

1. Date of current (HCFA item #14) must never be over 60 days old.


2. X-ray date must be less than 12 months old (364 days or less), or when no x-ray present, a P.A.R.T. form must be completed each and every visit. 


3. Diagnosis must make sense and match S.O.A.P. Notes to support the care rendered.


4. Lack of complete documentation by Federal Standard to proven Medical Necessity.

S.O.A.P. Notes are not the only Chiropractic documentation necessary to make a claim payable.  (Documentation is a federal document.)

Need help and/or assistance so that you can survive a Medicare audit? Please give me a call at (618) 395-3800 or consider ordering or Chiropractic Medicare DVD and booklet - Dr. Street

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.