Medicare Audit Letters Hit Chiropractors Starting August 2010
Every Medicare carrier in the country has been assaulting my inbox recently with “ALERT” emails designed to make chiropractors aware of studies being conducted by the Comprehensive Error Rate Testing (CERT) program. I am not sure if we are at the equivalent of Code Orange or Code Red at this point, but the profession is definitely on Medicare’s “elevated risk” alert system in some fashion. So, in case you haven’t heard, may this post serve to Paul Revere the chiropractic community to be on guard — Medicare is coming, Medicare is coming! Read More
Are Your Chiropractic Revenues Tied to Emotions or Logic?
When faced with decisions on major life purchases – house, car, building purchase, even expensive remodels or repairs – most of us responsible adult chiropractors tend to do some comparison shopping. We may go out and get three or four quotes, make a list of the pros and cons and then pick the best choice, right? Read More
Random Thoughts Episode #136: Chiropractic Audits, Business Building & Success
I’m on the road for the next couple weeks traveling for a number of on-site consultations with clients so this blog post will be a summary of random thoughts on the most common questions that repeatedly brought to my e-mail inbox. Read More
Selling Chiropractic Products and Billing Insurance
Many chiropractors have realized the benefits of offering products for sale to our patients. Whether it’s the convenience factor for the patient, our ability to control quality or brand use, or the fact that we want to be able to help our patient’s outcomes, products make sense.
Unfortunately, some chiropractors have a difficulty in making the sale of products make financial sense.
Worse, if you are the type of DC to stock your office with every “hot” new product that catches your fancy, only to quickly lose interest in it a few weeks later, product inventory and sales can become a financial drain on your profitability. Read More
The Best of…Strategic Chiropractor Blog Flashbacks

In business and in life, it is helpful to go back and review the basics, to take a look at where you’ve been and where you want to go.
Today’s blog post feature’s 3 links to our most popular columns of the past – in case you missed them – or in case you need “a refresher course.” (pardon the Fletch reference)
Here they are (in no apparent order):
Enjoy!
Tom Necela, DC, CPC, CPMA
Medicare Releases Chiropractic Medical Review Findings for the 1st Quarter

Recently, a Medicare carrier (Palmetto GBA) released their 1st Quarter results of Medical Reviews they have been conducting. Even though Palmetto is only one of several carriers who administer claims on behalf of Medicare, their findings are relevant to chiropractors and, in my experience, reflective of trends across the chiropractic profession at large.
The goal of the medical review program is to reduce payment errors by identifying and addressing documentation and billing errors concerning coverage and coding. In their reviews, Palmetto GBA identified ten problem areas for the first quarter of 2010. These areas were as follows:
- Split/shared visits
- Signatures
- Labels/Diagnostic Testing
- Hospital & Nursing Facility Discharge Services
- Chiropractic Services
- Therapy Services
- Individual Psychotherapy Services
- Evaluation & Management Services
- Legibility
10. Teaching Physician Services.
Please note this is not an all-inclusive list but does reflect the majority of documentation issues discovered during the review process. Of this list, however, three items have direct application to chiropractic reimbursements in the Medicare program.
So let’s discuss these three “Frequently committed errors”:
- Signatures. Put simply, Medicare requires an “identifier” for services provided or ordered. That identifier is your signature – either in handwritten or electronic form. Signature stamps in your documentation are not acceptable per Medicare Signaure Requirements (See section 3.4.1.1 B) Quite frankly, this is so basic that it is ridiculous that it even makes the top ten. Apparently, despite its simplicity, most physicians seem to overlook it.
- Chiropractic Services. As a relatively small profession, we should not even make the top ten hit list. We did, however, so now it is our responsibility to correct these problems asap as a profession. Palmetto found chiropractic documentation to be lacking in the area of Treatment Plans. More precisely, chiropractors were missing treatment plans with specific objective, measurable treatment goals. Follow thru with these specific objective treatment goals on subsequent visits was also often omitted. Difficult? Not very. Documented? Apparently, not very often. Can you fix this, doctor? Definitely!
- Legibility. If this is not the biggest commercial for EMR, I don’t know what is! Again, there is no reason any physician should be getting dinged for this one. Alas, I have seen many of your notes and I sadly agree, that they are barely legible, sometimes only to the highly trained eye (yours and that of your longstanding staff) – and sometimes, even you cannot decipher your own notes. Put simply, if your notes cannot unquestionably be read by a third-party without eliciting a migraine or use of some special telescopic lens, it is high time to get on EMR. There are plenty of good systems out there. In fact, ANY system that produces legible documentation is better than marginal handwriting – and I have yet to see an EMR system that fails to product legible documentation!
In summary, we chiropractors need to get our act together pronto – not only for Medicare, but for all third party payers. The items above are not difficult to fix, but I realize that some of you are overwhelmed by how much work you have to do to bring your documentation, billing and coding up to acceptable standards. Others may be so consumed with building your business that you literally don’t have time to look up and see the arrow sailing directly at the target on your chest. And some of you are just plain tired of putting out the fires in all these areas due to a lack of solid systems that both maximize your reimbursements and minimize your audit risk.
The good news is: help is available. And while it is a physical impossibility for me to assist all of you with these needs let alone answer the truckload of emails I receive per month on chiropractic billing, coding and documentation questions from random chiropractors at large! But I am willing to offer a FREE, no obligation look under the hood of your practice for those of you willing to invest the time and effort into completing a Practice Analysis Questionnaire. Download it, complete it, fax it in today and take a concrete step towards improving your practice, your business, your piece of mind and your life.
To Your Success!
Tom Necela, DC, CPC, CPMA
P.S. Not sure what can be done with YOUR practice? Take a look at what my clients have to say about the transformations they have achieved in their practice!
Solutions to Your Chiropractic Billing Problems
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How Medicare's New Consult Code Policy Affects Chiropractors

For those of you chiropractors who have been following Medicare’s new consult policy that recently went into affect, you may feel like we are yet again victims of another Medicare scheme to pick our pockets of the few reimbursements we do receive.
Recently Medicare removed reimbursement for Consultation Codes (99241-99245) and the impact is being felt across many health disciplines, including chiropractic. If you are unfamiliar with using Consult Codes, you have likely been missing out on significant income opportunities by documenting your services accurately.
Chiropractors, for the most part, view the consult as the time when we meet with a New Patient, answer a few of their questions and discuss the benefits of chiropractic care prior to actually performing an examination on the patient. This does NOT in any way meet the CPT definition of a consult code (99241-99245) and should never be billed as such.
On the other hand, a true consult occurs when a patient arrives in your office at the request of another physician. In other words, the other doctor (an MD, for example, is common) tells the patient to seek your professional opinion or expertise as a chiropractor. In this type of situation, with proper documentation and conditions met, you can bill a consult code (99241-99245) in place of your normal E/M code and (here’s the reason for their popularity), these codes will pay significantly better than standard E/M codes.
So, if your office receives MD referrals regularly, you have been missing out on a great opportunity to increase your income that, unfortunately, may now be drying up. For example, a typical billing of 99203 may be $100, whereas the consult equivalent of 99243 may be $150. I know several clinics who have increased reimbursement by thousands of dollars per year over standard E/M fees because of consult codes.
As of January 1, 2010, Medicare has indicated that it will no longer reimburse consult codes. For DC’s, we may view this is as no big deal since Medicare does not reimburse us for exams anyway. Unfortunately, since most third party payers and commercial insurance companies (such as BCBS, Aetna, Cigna, etc) use Medicare as a basis for payment decisions, many other insurance companies have stopped paying for consults as well! And that can be a big deal for us!
Based on this, I would recommend two action steps for you to take:
- Contact your large payers to determine if they are still paying consult codes. If so, keep (or start) using them until further notice.
- Eliminate billing consult codes to payers who have indicated that they are denying the code.
- Document the consult for either #1 or #2 as it is still important for the legal record, to indicate that the patient was a consult and that you have performed this services upon request from another provider. You may not be paid but you are still obligated to report the service as rendered.
While many would agree that Medicare’s policies frequently appear to torture chiropractors, this one has far reaching impact that crosses the line towards other payers as well. But, as mentioned previously, all payers have not yet adopted this new policy so be sure to utilize these codes while you can.
In the meantime, if new developments about this occur or if similar, new opportunities comes our way, I will be sure to let you know! And for those of you who are wondering if you are missing out on any other items related to billing, coding or documentation that would help you improve your reimburesements, the answer is likely “YES!” Take some time to fill out a FREE Practice Analysis Questionnaire and I will be glad to discuss how I may be able to specifically assist your clinic in this area, while also protecting you from unecessary audits due to your billing, coding or documentation mistakes!





