Category Archives: Medicare Audit

Medicare, Yada, Yada, Yada: Fraud, Waste and Abuse Training.

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OK, I admit it. Medicare is not the most glamourous topic to write about, nor does much of it pertain to our world of the chiropractic profession as we know it. However with that said, I am doing due diligence for you and fulfilling my duty to inform you of the necessary requirements a Covered Entity must follow (that’s us included!) to keep the Office of Inspector General off our backs and to help you take preventive measures so you’re not sending back reimbursement money you earned from providing patient care.

Because . . . based on my observations in the field – and this is a review for those of you who read our PM&A articles and utilize our library- how many of you know, for example, what a Part C Medicare plan is? How many of you know that all Part C providers are required to undergo annual Fraud Waste and Abuse training?

Second example: How many of you are aware that Medicare, starting in April of this year and going into April of 2019, is sending all of their beneficiaries new ID cards in an effort to do away with social security numbers for the sake of safeguarding identification?

So how do my two examples above directly impact you, your practice, and your bottom line?

Let’s circle back to the first example. A Part C Medicare Plan is known as a Medicare Advantage Plan. It oftentimes covers more services than a straight Medicare plan does. HMO/PPOs such as Humana and Blue Cross Blue Shield have developed their own Medicare Advantage Plans and offer them to their policyholders, your patients. A patient who signs up for an Advantage Plan must also be enrolled in Medicare A (hospital), and Medicare B (outpatient provider services). Medicare Part C providers to date have been required to, annually, undergo what is called Fraud, Waste and Abuse Training. Let’s take each of the three words and define them from the Medicare and Medicaid world.

  • Fraud is known intent to deceive in order to collect money from the Medicare program illegitimately.
  • Waste is overutilization of services or other practices that, directly or indirectly, result in unnecessary costs to the healthcare system, including the Medicare and Medicaid programs. It is not generally considered to be caused by criminally negligent actions, but by the misuse of office and/or practice resources.
  • Medicare Abuse includes practices that result in unnecessary costs to the Medicare program such as over or underutilizing services. You are probably familiar with the Quality of Care initiatives such as MIPS/MACRA and the EHR incentives, implemented to help combat abuse. Common types of abuse include:
    • Billing for unnecessary services
    • Overcharging for services or supplies
    • Misusing billing codes (upcoding) to increase reimbursement*

*Downcoding is also a misuse of billing codes. Stop doing it. Although not intended to increase reimbursement it is a red flag to Medicare, and your services will be questioned as to if they were “medically necessary.”

Back to the training . . . I urge you now to complete this training by the end of December. It is intended for doctors and staff. Download the PowerPoint below, read thoroughly and after completion have each staff and doctor sign off to attest, they read through the PowerPoint. The sign-off can be as simple as logging signatures and completion date in a notebook or a spreadsheet. It is not necessary to print out the PowerPoint. Oh, and many insurance contracts require this training as a contract obligation to be part of their network as well. You can access Medicare’s training PowerPoint here: Fraud, Waste and Abuse

Referring back to the second example of new Medicare cards. You can review our previous article and checklist here: New Medicare Beneficiary Indentifiers to be Assigned Your Patients

Your staff should be asking Medicare patients for their new cards, making a copy, and making sure the address in your practice management program matches the address the Social Security office has on file. If there is a mismatch like the patient has moved and not updated their address, you will have problems getting reimbursed. Make sure your Insurance Profiles in your programs have the new Medicare IDs.

Stay tuned for more helpful articles like this. If you have any questions on the above, contact me! I’m here to help.

Lisa Barnett
920-334-4561
lisa@pmaworks.com

And remember . . .
“The Future Will Be Our Results” (Clarence Gonstead, D.C.)

Has Your Office Been Target by Medicare for an Audit?

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Ms. Lisa Barnett with Petty, Michel and Associates specializes in preventing Medicare Audits. She has helped those who have already been targeted find a fast and safe way out of trouble.

You are not alone…. Things do Happen…..
You are busy and possibly you have overlooked a certain requirement. Your computer has gone through updates and you have not kept up. Or possibly your documentation is simply inadequate in the eyes of medicare or the government.

Whether you are faced with a prepay audit or a post payment audit. I can help !

With 10 years of experience in the chiropractic industry and with documentation; and a chiropractic advocate for 30 years I care and I want to help.

Call today for your complimentary phone consultation and record review. 920-334-4561

Medicare Audit Emergency Response Number

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Medicare Audit Emergency Response Number:     

920.334.4561

 

The Medicare Audit Preparation(MAP) is available to chiropractors nationwide. This is an emergency response program and on-site appointments are scheduled based on availability. Do NOT send records without calling us first.

The MAP program covers up to three full days (24 hours) in your office, plus 90 day off-site follow up as needed. The cost is $4,995 prepaid*. PM&A management clients can receive a 20% discount if they are active and current members.

Call for terms and conditions for this service. 920.334.4561

*Travel expenses may apply

 

Are You One of the 8500 Who Received a Letter From Medicare? Keep Calm and Don’t Panic

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Have you received a fax or letter from Center for Medicare/Medicaid Services regarding Comparative Billing Reports?  Don’t panic – call me and I will provide an onsite assessment at your practice to ensure your documentation, billing, and coding stay compliant.

Call Lisa:  nine two zero 334-4561

Email Lisa:  lisa@pmaworks dot com

MACRA- New Info on Medicare!

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rs-medicare-info-icon

New Info on Medicare!

Happy Holidays Chiropractic Friends!

First snowfall always seems to bring renewed energies and hope – my wish is you experience this, too.

Are you ready for January 2017? Ready or not, here it comes. Today I want to introduce and give you some of the latest and greatest on what’s happening with the new Medicare reimbursement model also beginning our new year.

To start with, six new acronyms to introduce to you: MACRA, MIPS, CHIP, APM, SGR, CPIA

  • MACRA: Medicare Access CHIP Re-authorization Act of 2015
  • MIPS: Merit-Based Incentive Payment System
  • CHIP: Children’s Health Insurance Program
  • APM: Advanced Payment Model
  • SGR: Sustainable Growth Rate
  • CPIA: Clinical Practice Improvement Activities

Here’s a bit of background for you regarding the initiative. In April 2015, President Obama signed into law the Medicare Access and CHIP Reauthorization Act 2015 (MACRA). This is an act to transition Title XVIII of the Social Security Act to the Medicare sustainable growth rate and strengthen Medicare access. How? By improving physician payments and making other improvements, like the Children’s Health Insurance Program. We could say MACRA is the umbrella to the program.

What is the purpose of the change in reimbursement model? The purposes include simplifying reporting for the convenience and ease of the providers participating; decreasing the current costs of healthcare, allowing patients the best quality of care; and to make patient information sharing safe and easy. The blueprint for pay for performance is the Merit-Based Incentive Payment System, and the goal is to create an acceptable payment system for physicians and the program.

Who are the stakeholders in the broader MACRA program? They include beneficiaries (your patients), businesses, payers, providers, and state partners.

Are you eligible to participate?

Both participating and non-participating providers are eligible to participate if you meet both of the following criteria: 1) Have seen 100 or more unique patients in a year, and 2) Have billed for covered services at $30,000 or more a year. You are exempt from participating in 2017 if 2017 is your first year as a Medicare provider. You are also exempt if you do not meet one of the two criteria above.

How will it work?

CMS has indicated through various webinars that they will notify via written communication if you are or are not eligible to participate. Once you learn of your eligibility, the program will require participating providers to report on three categories for the Merit-Based Incentive Payment System:

  • Quality (i.e., Physician Quality Reporting System, also known to you as PQRS but with some tweaks).
  • Practice Improvement, focusing on clinical quality measures. For examples, patient outcomes; patient engagement and compliance; adherence to your practice systems and guidelines.
  • Advancing Care Information (this is the technical component; i.e., Meaningful Use and minimum five measures recorded in your practice’s healthcare technology).

Additionally, if you are eligible to participate and choose not to, there will be a negative adjustment of 4% to your Medicare reimbursement. If you are eligible and do choose to participate, you may receive a positive adjustment of 4 to 9% depending on your level of reporting involvement, as well as a minimum 0.5% bonus for exceptional performance if your final reporting score meets or exceeds a certain point value.

You will have two reporting options: You may report for the entire 2017 calendar year, or you may report for the partial year, one quarter, and may begin no later than October 2, 2017.

PM&A will continue to monitor any changes to the above information.

In addition, I will be conducting onsite MACRA readiness assessments at chiropractic offices and am available to visit yours. Please contact me if you are interested in learning more!

Best,

Lisa Barnett, Consultant
Petty, Michel & Associates

Call: nine two zero.334.4561

Email: Lisa@pmaworks dot com

Rock Your Coding World! How to Evaluate Your Coding for Maximum Reimbursement

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Lisa J. Barnett

Lisa J. Barnett

Download a PDF of this article

Hello Friends in Chiropractic!

Hope you had an awesome summer and took several opportunities to soak in some UV and Vitamin D.

This month I’d like to both expand on my July Medicare Documentation article and coach you on self-auditing evaluation and management (E/M) coding for reimbursement. Are you consistently under-coding your E/M services? It is not benefiting you to do this because more than likely you’re meeting required elements and not getting the best reimbursement available.

So, what exactly does an auditor, be it Medicare or a Commercial Payer look for in determining reimbursement for your evaluation and management services? It is pretty simple and based on both quality and as it turns out, more importantly, quantity of certain elements. Let’s look in depth how you can self-audit your E/M services*:

First, a coding history and review. In 1992, the current E/M codes were introduced as a result of a ten-year study by CMS(Centers for Medicare and Medicaid Services) and the AMA(American Medical Association). Then in 1995 and 1997, CMS and the AMA developed documentation guidelines (DG) for use of these E/M codes.

Without re-inventing the wheel, let’s lay out how you determine which code to use for your patient evaluations and management of care. To review,

  • New patient E/M codes include 99201, 99202, 99203, 99204, and 99205.
  • Established patient E/M, or re-exam, codes include 99211, 99212, 99213, 99214, and 99215.

Charting out information from CMS and ACA’s ChiroCode book, here is what we have as quantifiable elements to determine which code to bill for. Keep in mind that Necessity of Care drives our discussion below.

History, Exam, Complexity of decision-making are the three main elements in the evaluation and management note.

Let’s now diagram out for you each code and corresponding description of each element, using both New Patient and Established Patient criteria. What differences do you see? Which descriptions share commonality?

NEW PATIENT

 CODE  HISTORY  EXAM

 COMPLEXITY OF DECISION-MAKING
IN MANAGEMENT OF CARE
99201 Focused/Minor severity  Focused Straightforward
99202  Expanded/Low-to-moderate severity  Expanded  Straightforward
99203  Detailed/Moderate Severity   Detailed  Low
99204  Comprehensive/Moderate to high severity   Comprehensive  Moderate
99205  Comprehensive   Comprehensive  High

 

ESTABLISHED PATIENT

 CODE  HISTORY  EXAM

COMPLEXITY OF DECISION-MAKING IN MANAGEMENT OF CARE
99211 No key component(s) required No key component(s)  required No Key component
99212 Expanded/Low-to-moderate severity Expanded Straightforward
99213 Detailed/Moderate severity Detailed Low
99214 Comprehensive/Moderate to high severity Comprehensive Moderate
99215 Comprehensive Comprehensive High

 

Building on that, here are the quantified components indicating the minimum number of each component’s required presence in the note to code appropriately and at the maximum level:

NEW PATIENT 

HISTORY  EXAM

 COMPLEXITY OF DECISION-MAKING
IN MANAGEMENT OF CARE
 Code Chief Complaint HX  of Present Illness  Review of Systems Past Family/ Social HX  Exam (1997 DG)  Diagnoses  Data to be reviewed; # of Complaints  Risk Factors
99201 1  1  N/A  N/A  1 in affected body area  1  1  Minimum
99202 1  1-3  1 N/A  1-5  1  1  Minimum
99203 1  4+  2-9  1  6-11  2  2  Low
99204 1  4+  10+  2-3  12+  3  3  Moderate
99205 1 4+ 10+ 2-3 All components 4 4 High

All 3 elements are required in the new patient note to consider reimbursement: History, Exam, Complexity

ESTABLISHED PATIENT 

HISTORY  EXAM

 COMPLEXITY OF DECISION-MAKING
IN MANAGEMENT OF CARE
 Code Chief Complaint HX  of Present Illness  Review of Systems Past Family/ Social HX  Exam (1997 DG)  Diagnoses  Data to be reviewed; # of Complaints  Risk Factors
99201 1 N/A  N/A  N/A N/A N/A N/A  N/A
99202 1  1-3 N/A N/A  1-5  1  1  Minimum
99203 1 1-3  1  1  6-11  2  2  Low
99204 1  4+  2-9  2+  12+  3  3  Moderate
99205 1 4+ 10+ 2+ All components 4 4 High

Two (2) out of the 3 elements are required in the established patient note to consider reimbursement: History, Exam, Complexity

As you may deduce from the above established patient table, 99211’s are rarely used in chiropractic offices. Can you see why?

Additionally, give your current score an extra two points for management of care, i.e., reviewing old records and summarizing in the note stability/worsening of condition, or, two points for obtaining history from someone other than the patient. Add one point for diagnostics performed and reviewed, (i.e., x rays).

Finally, make sure to attached your -25 modifier on all E/M codes if you are giving a CMT on the same DOS.

Have a specific patient in mind and you’d like to find out if you coded and billed at the most appropriate and highest level? Contact me on how you can qualify for a complimentary audit!  Call 920.334.4561 or email lisa@pmaworks.com

Sincerely in Chiropractic,

Lisa Barnett,
PM&A Coach and Consultant
Where Managing by Numbers and Progress Says It All.
My purpose is to be the Best Chiropractic Advocate in the World

*EHR systems may already have built-in features to automate the components for you via their macros/templates.References:

  • American Chiropractic Association ChiroCode Deskbook, 2014-2017
  • Centers for Medicare and Medicaid Services, 1997 Documentation Guidelines for Evaluation/Management Services, Reference II, Medicare Physician Guide, A Resource for Resident Physicians, Practicing Physicians, and Other Healthcare Professionals
  • Centers for Medicare & Medicaid Services, Medicare Learning Network, ICN006764, August 2015, https://www.cms.gov/Outreach-and-Education/Medicare-Learning-Network-MLN/MLNEdWebGuide/Downloads/97Docguidelines.pdf
  • Gwilliam, Evan M., DC, MBA, BS, CPC, NCICS, CCPC, CCCPC, CPC-I, MCS-P, CPMA

List of Components:
History of Present Illness – Elements:
Location (example: left leg); Quality (example: aching, burning, radiating pain); Severity (example: 90 on a scale of 1 to 100); Duration (example: started 3 days ago); Timing (example: constant or comes and goes); Context (example: lifted large object at work); Modifying factors (example: better when ice/heat is applied); and Associated signs and symptoms (example: numbness in toes)

Review of Systems:
Constitutional Symptoms (for example, fever, weight loss); Eyes; Ears, Nose, Mouth, Throat; Cardiovascular; Respiratory; Gastrointestinal; Genitourinary; Musculoskeletal; Integumentary (skin and/or breast); Neurological; Psychiatric; Endocrine; Hematologic/Lymphatic; and Allergic/Immunologic

Past Family/Social History:
Past history includes experiences with illnesses, surgeries, injuries, and treatments/medications. Family history includes a review of medical events, diseases, and conditions that may place the patient at risk. Social history includes an age-appropriate review of past and current lifestyle activities.

To download the article in it’s entirety click the here [LINK]

The Importance of Compliance in a Chiropractic Office – HIPAA, Covered Entity, OSHA, HITECH

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Lisa J. Barnett

Lisa J. Barnett

HIPAA, Covered Entity, OSHA, HITECH – – Compliance. What’s happening in the world of compliance and why do you as a chiropractor need to be educated and remain in the know? Find out below . . .

First and foremost, according to the Health and Human Services (HHS), chiropractors are included in the covered entity category, and this is regardless of whether or not you have received Electronic Health Records incentive monies. Covered entities are required by federal law to comply with all areas of protected health information and employee safety standards. Impact of non-compliance? In February 2016, a covered entity was fined $239,800 for non compliance.

Further, according to a March 2016 survey among small practices designated as covered entities, 60 percent of the 900 plus professionals surveyed are still unaware of pending compliance audits, and 58 percent have not appointed a securities/privacy officer in their practice. Audits to our profession are forthcoming, and we cannot opt out. Keep reading on how to safeguard yourself and your practice. Also keep in mind that it takes approximately 40 to 50 hours to develop and secure a compliance program.

The three main areas of compliance you need to be aware of, educated in, and be an active participant include: HIPAA, OSHA, and IT Securities.

Health Insurance Portability and Accountability Act
The Health Insurance Portability and Accountability Act (HIPAA) law of 1996 was enacted to improve the portability and accountability of health insurance coverage, and it brought individual privacy rights to patients and requires that we notify them of their rights. It also serves to eliminate fraud, waste, and abuse in healthcare. The focus here is to safeguard your practice by securing personal (patient) health information (PHI) and personal identifiers, be it paper or electronic (ePHI). This can include data encryption, secure messaging, compliant Cloud storage, compliant software, and unique password setups. One of the areas I assess when I visit a clinic is locating where the patient paper files are kept and if they are well out of viewing from others.

Your HIPAA requirements to be compliant at the clinic level include:

  • Designating a compliance/privacy officer whose primary responsibility is to ensure compliance with the regulations
  • Establishing and implementing at least annually, training programs for all employees and doctors.
  • Implementing appropriate policies and procedures to prevent intentional and accidental disclosure/release of PHI or ePHI. Encrypting your data for example will lower your chances of ransomware or cyberattacks.

OSHA
The United States Occupational Safety and Health Administration (OSHA) Act was signed by President Nixon in December 1970. It is designed to protect worker safety and promote healthy work environments. Some of you Docs have been involved in workplace safety and onsite workplace assessments in factories. Kudos to you! You were advocating OSHA’s mission by: Educating your client and their employees on workplace safety by conducting posture and ergonomic assessments, and finding the best ways for workers’ compensation patients to get back to work and continue contributing safely and appropriately within their restrictions.

At the clinic level (can be delegated), your requirements to meet OSHA requirements include:

  • Displaying the required workplace safety and employee rights posters for all employees to review
  • Establishing annual training for yourself and your employees. Local fire departments usually are able to conduct these trainings and are willing to include other participants.
  • Developing a written emergency plan in case of fire, severe weather, etc.
  • Drawing up an exit plan and post for employees and patients to see. See example below:

evacuation map

  • Developing written procedures (universal precautions) to minimize risk exposure to bodily fluids such as blood, vomit, saliva.
  • Obtaining Safety Data Sheets for disinfectants used at the clinic, as well as if you process X-rays.
  • Have handy your Quality Assurance X-ray manual, follow it, and ensure it is accessible to those who take/process X-rays.
  • Ensuring ergonomic workplace assessments are conducted at the clinic and documented. This could include posture screenings for your employees and requiring stretch breaks – for you, too!

Information Technology (IT) Security/HITECH

The Health Information Technology for Economic and Clinical Health (HITECH) Act, enacted as part of HIPAA and the American Recovery and Reinvestment Act of 2009, was signed into law on February 17, 2009, to promote the adoption and meaningful use of health information technology. Section 1176(a) of the Social Security Act was revised during this timeframe to allow for significant monetary penalties up to $1.5 million for breaches/violations of protected health information. However, an interim revision (later known as The Omnibus Rule) set prohibitions on enforcing such significant monetary penalties if it was found in investigation that the covered entity did not know and with the exercise of reasonable diligence would not have known of the violation. In these cases, the breaches were punishable under the lowest tier of penalties, and further, prohibited the imposition of penalties for any violation corrected within a 30-day time period, as long as the violation was not due to willful neglect. A final ruling in January 2013 reiterates all of the above standards.

Your responsibilities to get IT Securities compliant include:

  • Assigning a securities officer
  • Conducting a risk assessment
  • Ensuring your EHR vendor and billing clearinghouse are HITECH/HIPAA compliant
  • Ensuring every vendor you work with has signed a Business Association Agreement with your office and you have those Agreements on file. These need to be updated at least annually.
  • Ensuring the clinic’s computer systems are backed up regularly, have virus-checking software, firewalls, and encrypted operating systems
  • Establishing securities policies and procedures, including on your social media networks.
  • Creating a disaster recovery plan
  • Creating a policy and procedure of notification, in the event of a data leak or leak of PHI/ePHI

Impact of non-compliance? Another covered entity was fined $25,000 for posting patient information online.

Feeling overwhelmed? We can help. Contact me on how you can get an initial Compliance Assessment and a Medicare Documentation Assessment with a Report of Findings sent to you, for a ridiculous low price of $299!*

References:

  • nueMD Cloud-based health information technology, http://www.nuemd.com/webinars
  • HIPAA Journal, http://www.hipaajournal.com/
  • United States Health and Human Services, http://www.hhs.gov/hipaa/
  • United States Occupational Safety and Health Administration, www.osha.gov/
  • Federal Register/Rules and Regulations Publication Vol. 74 No. 209
  • Federal Register/Rules and Regulations Publication Vol. 78 No. 17
  • Emergency Exit Diagram: www.steamwire.com business continuity templates

*Mileage cost may apply.

Medicare in Your Chiropractic Office: Is Your Documentation In Order?

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Lisa J. Barnett

Lisa J. Barnett

Have you ever thought you could be both a great documenter and repeatedly educate your patients on their innate intelligence . . . if you only had the time? Keep reading on how to both bulletproof your documentation for a potential audit and maintain the energy of our profession’s principles.

Let’s help build your ammunition.

First . . . did you know that the US Health and Human Services advised Medicare to target chiropractors to curb questionable and inappropriate payments, projected at $280,000,000? Seriously! And clinics are, as I write this, being audited. How do I know? Because we’re receiving phone calls and emails asking, “What do I do? I received a letter from Medicare.” As a result, I’m traveling around to help chiropractic offices prepare.

To insure yourself and what you’ve worked hard for, make sure your documentation (that is, every single note in the patient’s file/your EHR software) is citing the following information:

  • History Obtained at Initial Visit:
    • Symptom(s) causing patient to seek care
    • Family history if relevant
    • Past health history (general health, prior illness, injuries, hospitalizations, surgeries, current medications)
    • Mechanism of trauma
    • Quality and character of symptoms/problem
    • Onset, duration, intensity, frequency, location, radiation of symptoms
    • Aggravating or relieving factors
    • Prior interventions, treatments, medications, secondary complaints
  • Initial Visit or New Onset
    • History (as stated above)
    • Description of the present illness:
      • Mechanism of trauma (how did it happen?) For example, getting out of bed, twisting, gardening.
      • Quality and character of symptoms/problem
      • Onset, duration, intensity, frequency, location, radiation of symptoms
      • Aggravating or relieving factors,
      • Prior interventions, treatments, medications, secondary complaints
      • Symptoms causing patient to seek care. Symptom(s) must be related to the level of the subluxation documented.
    • Evaluation of spine/nervous system through physical examination.
      • PART: pain and tenderness, asymmetry/misalignment, range of motion abnormality, tissue, tone changes
    • Diagnosis: Primary diagnosis must be a subluxation, including the level or identified descriptive term of location, i.e., condition of the spinal joint involved, direction of position assumed by the named bone.
    • Treatment plan, to include the following:
      • Recommended level of care (duration and frequency of visits), specific goals, objective measures to evaluate treatment effectiveness, date of the initial treatment.
      • Though not a documentation requirement, this is where you will educate the patient face to face, as to their subluxation and what will happen if they don’t get it corrected, as well as educate them on their innate intelligence.
  • Subsequent Visits:
    • Review of chief complaint, changes since last visit, systems review if relevant
    • Physical Exam
      • Exam – area of spine involved in diagnosis
      • Assessment of change in patient condition since last visit
      • Evaluation of treatment effectiveness.
      • Though not a documentation requirement, this is a perfect time to re-educate the patient on chiropractic principles.
      • Documentation of the presence or absence of a subluxation
      • PART: pain and tenderness, asymmetry/misalignment, range of motion abnormality, tissue, tone changes
    • Documentation of treatment given on day of visit (technique(s) used and areas adjusted)
    • Progress or lack thereof, related to goals and treatment plan (is the patient meeting goals?)

Let me be clear: The above documentation requirements are not PM&A’s. They are Medicare’s.

Other Tips:

  • Your subjective findings in initial visits/new onsets should tell a story about what happened, how it happened, and when it happened.
  • The Visual Analog Scale (VAS) is not sufficient documentation as your sole objective tool. Use additional tools to measure objectives findings.
  • See below for a typical VAS:

VAS-Lisa

  • You should self-audit your documentation on a regular basis.

In closing, get out there, do what you do best to attract and help anyone with a spine, and follow the above documentation requirements to armor yourself in the event of an audit by Medicare and other payers. Need help staying relaxed and focused, and getting paid? Give us a call. That’s why we’re here.

Sincerely in Chiropractic,
Lisa

Lisa is now providing a no charge initial consultation regarding your Medicare documentation. You can contact at (920) 334-4561 or by email at Lisa (at) @ pmaworks.com

More information on Lisa[LINK]

Download a printable copy of this newsletter [June newsletter]

Download a customizable copy of the Checklist: [Medicare Documentation ChecklistDOC]

Print Checklist (PDF)[Medicare Documentation Checklist-PDF]

 

Medicare, Chiropractic, and Computer Generated Notes

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Is Your Office Looking Into Computer-Generated SOAP Notes? Read This FIRST before you invest your cash!

Thinking that your documentation could use an upgrade? You are probably right, but before you invest in a software generated note system, know that Medicare frowns on most such programs and they could actually hurt you in an audit.

As we have been saying for years, there is no good shortcut out there for doing documentation. You have to follow Medicare’s guidelines and just because your software generates a half page typed SOAP, you may still be missing the mark.

According to ChiroCode Institutes recent alert:

Medicare carrier Noridian Administrative Services recently updated and reprinted a notice on Chiropractic Software-Generated Documentation. Apparently, the piece was generated because Noridian has seen an increase in the use of software-generated documentation for chiropractic services.  Here are a few key areas where software can begin to go wrong (according to Noridian):

– In general, most computerized documentation fails to provide individualized information necessary for reimbursement.

– Software-generated documentation is commonly identical to the letter, comma and space for different patients, with only minor word changes; therefore, it does not reflect medical necessity.  Services supported by repetitive entries lacking encounter specific information will be denied.

– Software-generated documentation often repeats the same phrases and sentences by simply rearranging the words to make it appear as if new information is being disseminated, but when compared to prior days notes, reflects the same or similar concepts.

You can read the whole article here: https://www.noridianmedicare.com/provider/updates/docs/chiropractic_software.pdf%3f. The article contains some humorous (at least to me) examples of  how the software, while randomizing text, generates almost identical SOAPs for different patients on different days.

Getting a Medicare CERT audit? Don’t send in your records without calling us first. See our website for more information on our exclusive Medicare Pre-Audit Documentation Review. LINK

Chiropractors – If You Get a Medicare Audit, Do You Know What to Do Next?

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Are You Prepared?

If You Get a Medicare Audit,
Do You Know What to Do Next?

If you haven’t already heard, CMS Medicare has launched a massive audit project aimed at chiropractic offices around the country. Executive Order #13520 “Reducing Improper Payments and Eliminating Waste in Federal Programs” has unleashed a random attack of chiropractors aimed at recovering an estimated $174,100,000 in over payments.

Medicare has hired two companies to start auditing chiropractors. There is no way to know if you will get a request for an audit, but I can tell you this from being on the road: very, very few clinics will pass a Medicare audit based on the documentation that I have seen.

That’s not to say you aren’t providing proper, necessary care. Far from that. The Medicare documentation requirements for the physician’s signature alone are three pages long.

So What Should You Do?

PM&A is prepared to help you. We have had 25 years of experience with Medicare audits and appeals. If you get a request for an audit, DON’T freak out. Do this instead:

  • Do not ignore it! You have 30 days to respond.
  • Do not let your staff photocopy and send the records out blindly!
  • Call our office immediately and request our special MPDR Program: MEDICARE PRE-AUDIT DOCUMENTATION REVIEW

We will come to your office & go through any requested records with a fine-tooth comb to assist you in ensuring that you have complete documentation for all services rendered, that each date of service is properly documented, that all PART forms are complete, and that active care modifiers have been properly used.

We will go over each entry in the chart with the treating doctor to ensure that every requirement of Medicare documentation is met for the service you rendered. If addendums need to be made, we’ll ensure that the addendums meet or exceed Medicare requirements.

We will also draft a follow up and Medicare Compliance Plan for your office for any areas that need to be corrected so that you can avoid potentially devastating pre-payment future audits or fraud charges.

We have successful fought AND WON on numerous Medicare audits. No other chiropractic management company can say that. A bad Medicare audit can cost well over $100,000 and thousands of staff hours – and more importantly, hurts your patients and their right to chiropractic coverage.

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Medicare Audit Emergency Response Number:     920.459.8500


The MPDR is available to chiropractors in WI, MN, IL, IN, & ND only. This is an emergency response program and slots will be limited to PM&A clients first, then first come. Do NOT send records without calling us first.

The MPDR program covers up to two full days (20 hours) in your office, plus limited follow up. The cost is $4,800 prepaid. PM&A management clients can receive a 20% discount if they are active and current members.

Call for terms and conditions for this service. 920.459.8500