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“The Toughest Chiropractic Billing, Coding, Documentation Questions Ever!” FREE Webinar!
“The Toughest Chiropractic Billing, Coding, Documentation Questions Ever!” FREE Webinar! avatar

Written by Tom Necela, DC, CPC, CPMA, CCP-P on December 1st, 2010

It’s time for the 3rd annual installment of “The Toughest Billing, Coding, Documentation and Collections Questions Ever!”

In this FREE webinar you will have a chance to get your most frustrating or confusing questions answered by Dr. Tom Necela – chiropractor, certified professional coder, certified professional medical auditor and certified compliance professional. Read More


How to Interpret Your Chiropractic Comparative Billing Report
How to Interpret Your Chiropractic Comparative Billing Report avatar

Written by Tom Necela, DC, CPC, CPMA, CCP-P on November 2nd, 2010

This past week or so, 5000 chiropractors nationwide received a “present” in the mail in the form of a Chiropractic Comparative Billing Report (CBR).  Even though I had previously reported that this would happen (see my previous post “Medicare Releases Chiropractic’s Comparative Billing Report Pilot”), my email inbox now knows what it must feel like to be a postal carrier during the holiday season.

Although, the CBR is not punitive or an audit per se, the report has certainly stirred up strong feelings in our profession and got a whole lot of people suddenly worried about their billing practices and level of audit risk.

At this point, it is not humanly possible for me to respond to all the emails that I have received on the CBR from the profession at large.

However, I will offer the following blog post to address many of the common concerns and questions I have received from chiropractors wondering what to do about their CBR. Read More


Medicare Issues Chiropractic Software and Documentation Alert
Medicare Issues Chiropractic Software and Documentation Alert avatar

Written by Tom Necela, DC, CPC, CPMA, CCP-P on September 21st, 2010

Medicare carrier Noridian Administrative Services (which administers Part B claims in Alaska, Oregon, Washington, Arizona, Montana, North Dakota, South Dakota, Utah and Wyoming) recently updated and reprinted a notice on Chiropractic Software-Generated Documentation that I think can serve to educate us as a profession.

Incidentally, although your specific carrier may not be Noridian, you should take note that most Medicare carriers generate the exact same news releases, alerts and notices each week so I wouldn’t be surprised if you don’t receive a similar “reminder” from your carrier.  Even if you don’t the information contained and summarized below can be crititical towards getting claims paid as well as avoiding denials and postpayment audits.

Apparently, the piece was generated because Noridian has seen an increase in the use of software-generated documentation for chiropractic services.  In and of itself, there is certainly nothing wrong with using EMR or even any form of computerized notes. So what’s their beef? Read More


Medicare Audit Letters Hit Chiropractors Starting August 2010
Medicare Audit Letters Hit Chiropractors Starting August 2010 avatar

Written by Tom Necela on August 17th, 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?
Are Your Chiropractic Revenues Tied to Emotions or Logic? avatar

Written by Tom Necela, DC, CPC, CPMA, CCP-P on August 3rd, 2010

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


The Final Word on Chiropractic EHR Stimulus Dollars (For Now)
The Final Word on Chiropractic EHR Stimulus Dollars (For Now) avatar

Written by Tom Necela, DC, CPC, CPMA, CCP-P on July 27th, 2010

The recent release (July 16, 2010) of the “Final Rule” regarding Meaningful Use criteria and EHR (Electronic Health Records) Financial Incentives has certainly prompted lots of questions from many chiropractors about how to obtain stimulus dollars for their EHR / EMR systems and what they need to do to qualify.

Below is a summary of some key points regarding EHR eligibility for those of you who don’t care to read the original documents or fact sheets on Meaningful Use and EHR Financial Incentives in their entirety: Read More


Random Thoughts Episode #136: Chiropractic Audits, Business Building & Success
Random Thoughts Episode #136: Chiropractic Audits, Business Building & Success avatar

Written by Tom Necela, DC, CPC, CPMA, CCP-P on July 20th, 2010

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


The Best of…Strategic Chiropractor Blog Flashbacks
The Best of…Strategic Chiropractor Blog Flashbacks avatar

Written by Tom Necela, DC, CPC, CPMA, CCP-P on May 10th, 2010

flashback

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
Medicare Releases Chiropractic Medical Review Findings for the 1st Quarter avatar

Written by Tom Necela, DC, CPC, CPMA, CCP-P on April 6th, 2010

detective

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:

  1. Split/shared visits
  2. Signatures
  3. Labels/Diagnostic Testing
  4. Hospital & Nursing Facility Discharge Services
  5. Chiropractic Services
  6. Therapy Services
  7. Individual Psychotherapy Services
  8. Evaluation & Management Services
  9. 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”:

  1. 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.
  1. 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!
  1. 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!


Correcting Chiropractic Billing Snafus, Altering Records & Advice from Bob
Correcting Chiropractic Billing Snafus, Altering Records & Advice from Bob avatar

Written by Tom Necela, DC, CPC, CPMA, CCP-P on February 22nd, 2010

altering records

In the wake of insurance denials, some chiropractors pose an interesting question in their attempt to get paid for what they do.  It is some variation of this:

“If I billed something incorrectly…or the insurance company denied a particular service…or procedure A was bundled with procedure B…can I change my records/billing/coding so I can get paid for this?”

Certainly, my loyal blog readers know that one of the two primary purposes of my writing this column is (1) to help you maximize reimbursements by getting you paid for ALL the work you do.  But this purpose is also coupled with keeping you compliant in your billing, coding and documentation while attempting to achieve my other goal for you, which is (2) to minimize your audit risk.

In other words, I would love to see every chiropractor paid well for all of the work they do (not more than they deserve, but not less) and, of equal importance, possess the proper documentation necessary to KEEP the money they earned.

Answering the question(s) posed then is not a simple “yes” or “no” but an “it depends.” Let’s explore this a little further.

Amendment of Records Can Be a Good Thing

Amendment of a medical record can be a good thing. Reviewing your records to check for accuracy and completeness and taking the time to amend them is common and commendable. We all know that the daily duties and pace of practice often cause us to spend less time taking notes that we may want to or that good documentation may warrant.  Therefore, a practice of reviewing notes before the day’s end, for example, can be a good way to catch any missed items needing documentation as well as prevent incorrectly billed or coded services.

Obviously, the best practice is to complete your records correctly the first time. But if you didn’t, you can make an addition or correction later. You must do so in a legitimate and above-board fashion—timely and not apparently an “alteration.” Different payers may have varying definitions of what constitutes “timely” documentation, but most appear to indicate that the note should be completed during the actual encounter of shortly thereafter.  Most payer descriptions I have seen of this seem to indicate “shortly thereafter” means within 24hours after treatment.

Avoid Alteration of Records

Let’s differentiate between the terms: “Amendment” or “Alteration.”  For our discussion, Amendment refers to the process of reviewing and/or correcting mistakes within a short period of time (as above) for the purposes of correction.  Alteration, on the other hand, does not quite convey the same corrective intent.

For example, if you alter your records once a lawsuit has been filed or an attorney has requested your records, it’s too late and this would not be considered a legitimate “correction” or amendment of the patient’s file.

Unfortunately, this is a common scenario: you receive a request for records, review your documentation, and see that some fact is omitted or some entry is inaccurate. You quite innocently think that you can “improve” the record.

Let me stop you there. Don’t do it.

Every state chiropractic board in the country has heard numerous cases of records alteration and, I am sure, cringes every time they have to review one.

In reality, the insurance company, plaintiff’s attorney, claim review company and who knows who else has likely already obtained a copy of your records in their original form. As the jury is shown both the original record and your “revised” record, you will see your credibility disappear before their eyes – even if the alteration of the record was innocent, helpful or minor.

At the least, any alterations you make in the records significantly after the treatment date can be viewed as self-serving. Taken to the extremes, it can also be regarded as a cover-up or potential fraud.  (See picture at start of blog for what technology can do to squash your attempts to alter records anyway!)

Adding To or Correcting Records

What should you do if you discover an omission? Suppose you review your earlier progress note and discover that you forgot to state that you made an appointment for a patient x-ray? Or what if you reviewed the x-rays and in the process of documenting your findings, inadvertently left a key finding out of your report?

Sometimes, omissions may not have clinical relevance but are needed for accuracy. For example what do you do when you discover that a simple typing error has made your 26 year old patient 62 years old?

In cases like these, adding a note can illustrate the fact that you are a conscientious chiropractor by demonstrating that you are careful enough to review your notes and concerned enough to add the missing information.

To properly amend records, you need to:

  • Put a notation in the margin next to the original entry: “see my note below.”
  • Enter another note at the time you discover the error. Write in the added information. Initial and date it.
  • Draw a single line through the incorrect entry. Make sure that the original entry is still legible.
  • Explain the correction. If possible, explain why the earlier note was incorrect, the reason for the error, and the reason the error was noticed.

On the other hand, erasing, using correction tape or fluid, or obliterating any documentation in the record is unacceptable and would be a big no-no that can land your tail in hot water.

Billing Snafus

Many chiropractors contact me – after the fact – about their claim denials, payment disputes or billing problems which may have occurred as a result of errors or ignorance.  Some of these problems are correctable.

If you legitimately performed a procedure, documented it correctly and simply forgot to bill for the procedure alongside the other services that were rendered during that visit, you may wish to submit a corrected claim and get reimbursed for this.  Provided you do this in a timely manner, the insurance should reprocess the claim and pay for your for the service.

Similarly, if an insurance company has denied your service based on a claim submitted with the wrong code on it (due to a human error, mistake, number dyslexia, etc), re-submit your claim for payment consideration.  In these instances, I find a short letter submitted with the corrected claim to be helpful. (i.e.  Dear Sirs,  I inadvertently billed for 58940 instead of a 98940.  There was no Oopherectomy performed, in part or total, during the course of the patient’s chiropractic visit nor was it my intention to attempt to get paid for one.  The service performed was…)

Some billing problems, however, should not be corrected.

For example, adjusting 3-4 areas of the spine (98941) and performing manual therapy (97140) in one of those same areas won’t fly with payers and will result in a denial.  If you have billed this out and find a rejection letter staring you in the face, you should not downcode your service to a 98940, re-bill it and hope to be paid for your “corrected claim.”

Presuming you did adjust three or four areas in the first place, it would be fraudulent to downcode because you are essentially lying to get paid.  Again, take your lumps and correct the issue.

Likewise, if you bill for a service only to find it denied, you should not re-submit the claim using a different code in an attempt to get paid.  Look in any coding book, page 1 or thereabouts and you will see instructions that read something like “Select the name of the procedure of service that most accurately identifies the service performed.”

Spaghetti billing methods (throw it to the wall, see what gets paid/sticks) are not advisable, inefficient and potentially fraudulent.

Parting Words of Wisdom…From Bob

So what do you do if you have a billing problem that causes you to lose money, but which you cannot correct if you wish to keep your nose clean?

  1. Identify and research the issue so that you can understand the problem.
  2. Seek experienced help.  Billing and coding errors rarely occur in isolation.  Typically, I find multiple errors that are costing my clients thousands of dollars in unrealized income or potential losses.
  3. For future purposes, and on the lighter side, see Bob Newhart’s classic advice on the matter below.  A little on the rough side, but technically accurate!  J

To Your Success!

Tom Necela, DC, CPC, CPMA


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