This year, there will be some major changes that will definitely need to be tracked along with some trends you definitely want to pay attention to. Here they are… Read More
Medicare Issues Chiropractic Software and Documentation Alert
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
The Final Word on Chiropractic EHR Stimulus Dollars (For Now)
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
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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!
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Correcting Chiropractic Billing Snafus, Altering Records & Advice from Bob
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?
- Identify and research the issue so that you can understand the problem.
- 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.
- 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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The 25 Meaningful Use Criteria for Chiropractic EMR Systems
Adopting an electronic medical records (EMR) system can net you up to $44,000 in government incentive money. Or can it?
Some of the most frequently asked questions I received in 2009 (which still continues through 2010) is in regards to how to select an EMR system and the stimulus funds that potentially go with EMR implementation.
The problem?
All stimulus incentives hinged on practices adopting “meaningful use” of the EMR systems in question. The problem? Up until December 2009, “meaningful use” was left undefined!
In other words, you could not get the money unless you were using EMR according to certain set criteria but no one went on record to establish exactly what those criteria were!
Unfortunately, the cloud was not exactly lifted this past December because the proposed rules for “Meaningful Use” are 556 pages long! Worse yet, industry experts don’t expect the final rule to be much different so knowing the proposed rule is essential to meeting meaningful use and getting paid.
So, then, how does one crack the mystery code and define meaningful use? Lost in those 556 pages are a total of 25 requirements your practice must meet to achieve meaningful use. Don’t worry, I will spare you the trouble of reading the electronic equivalent of War and Peace (which is far more difficult to understand and much less entertaining) and summarize the 25 points below.
But let me cut to the chase. For those of you who have recently purchased an EMR system or who are considering a purchase, don’t bank on getting those stimulus dollars just yet.
For those of you who are still considering getting an EMR system, let me go on record and state that I think that is a great idea for most practices. However…don’t purchase one just because you feel the stimulus dollars are going to be rolling in afterward.
Purchase one with the intent of having a system improve your clinical documentation, practice management and overall efficiency. Most will do that, provided you choose the right system to suit your needs.
Can’t decide which system to choose?
Given that you should take stimulus dollars out of the equation, there are certainly other factors to consider in choosing the right system for you. Before you make a $10,000 mistake, perhaps you should consider investing less than 1% of that figure into my “How to Choose a Chiropractic EMR System audio program.”
This 1.5 hour program (on 3 Audio CD’s) walks you through the thought process of how to make an intelligent decision on purchasing the right system for your practice. I won’t come out and tell you to buy X, Y or Z but teach you how to shop and the tough questions you should be asking to make sure that you are getting the right system.
Frustrated with Your Own System?
It’s not too late to start over and think strategically about what will be a better fit for you and your practice. I see far too many chiropractors who have expensive EMR systems collecting dust because they abandoned ship out of frustration and went back to paper.
There was a reason you chose to get EMR, you should find a system that you can actually use – they ARE out there! Again, before you run out and buy another program, consider a small investment in strategy, some collective wisdom and a system to make a good purchase – my “How to Choose a Chiropractic EMR System” audio program accomplishes all of these.
And now, as promised, here are the 25 “Meaningful Use” Criteria for eligible providers. (These criteria were taken from the proposed rule: Medicare and Medicaid Programs; Electronic Health Record Incentive Program.)
The List: 25 Meaningful Use Criteria
1- Objective: Use computer physician order entry (CPOE)
Measure: CPOE is used for at least 80 percent of all orders
2 -Objective: Implement drug-drug, drug-allergy, drug- formulary checks
Measure: The EP has enabled this functionality
3 – Objective: Maintain an up-to-date problem list of current and active diagnoses based on ICD-9-CM or SNOMED CT®
Measure: At least 80 percent of all unique patients seen by the EP have at least one entry or an indication of none recorded as structured data
4 – Objective: Generate and transmit permissible prescriptions electronically (eRx)
Measure: At least 75 percent of all permissible prescriptions written by the EP are transmitted electronically using certified EHR technology
5- Objective: Maintain active medication list
Measure: At least 80 percent of all unique patients seen by the EP have at least one entry (or an indication of “none” if the patient is not currently prescribed any medication) recorded as structured data
6- Objective: Maintain active medication allergy list
Measure: At least 80 percent of all unique patients seen by the EP have at least one entry (or an indication of “none” if the patient has no medication allergies) recorded as structured data
7 – Objective: Record demographics.
Measure: At least 80 percent of all unique patients seen by the EP or admitted to the eligible hospital have demographics recorded as structured data
8 – Objective: Record and chart changes in vital signs
Measure: For at least 80 percent of all unique patients age 2 and over seen by the EP, record blood pressure and BMI; additionally, plot growth chart for children age 2 to 20
9 – Objective: Record smoking status for patients 13-years-old or older
Measure: At least 80 percent of all unique patients 13-years-old or older seen by the EP “smoking status” recorded
10 – Objective: Incorporate clinical lab-test results into EHR as structured data
Measure: At least 50 percent of all clinical lab tests results ordered by the EP or by an authorized provider of the eligible hospital during the EHR reporting period whose results are in either in a positive/negative or numerical format are incorporated in certified EHR technology as structured data
11 – Objective: Generate lists of patients by specific conditions to use for quality improvement, reduction of disparities, research, and outreach
Measure: Generate at least one report listing patients of the EP with a specific condition
12 – Objective: Report ambulatory quality measures to CMS or the States.
Measure: For 2011, an EP would provide the aggregate numerator and denominator through attestation as discussed in section II.A.3 of this proposed rule. For 2012, an EP would electronically submit the measures are discussed in section II.A.3. of this proposed rule.
13 – Objective: Send reminders to patients per patient preference for preventive/ follow-up care
Measure: Reminder sent to at least 50 percent of all unique patients seen by the EP that are 50 and over
14 – Objective: Implement five clinical decision support rules relevant to specialty or high clinical priority, including for diagnostic test ordering, along with the ability to track compliance with those rules
Measure: Implement five clinical decision support rules relevant to the clinical quality metrics the EP is responsible for as described further in section II.A.3
15 – Objective: Check insurance eligibility electronically from public and private payers
Measure: Insurance eligibility checked electronically for at least 80 percent of all unique patients seen by the EP
16 – Objective: Submit claims electronically to public and private payers.
Measure: At least 80 percent of all claims filed electronically by the EP
17 – Objective: Provide patients with an electronic copy of their health information (including diagnostic test results, problem list, medication lists, and allergies) upon request
Measure: At least 80 percent of all patients who request an electronic copy of their health information are provided it within 48 hours
18 – Objective: Provide patients with timely electronic access to their health information (including lab results, problem list, medication lists, allergies)
Measure: At least 10 percent of all unique patients seen by the EP are provided timely electronic access to their health information
19 – Objective: Provide clinical summaries to patients for each office visit
Measure: Clinical summaries provided to patients for at least 80 percent of all office visits
20 – Objective: Capability to exchange key clinical information (for example, problem list, medication list, allergies, and diagnostic test results), among providers of care and patient authorized entities electronically
Measure: Performed at least one test of certified EHR technology’s capacity to electronically exchange key clinical information
21 – Objective: Perform medication reconciliation at relevant encounters and each transition of care
Measure: Perform medication reconciliation for at least 80 percent of relevant encounters and transitions of care
22 – Objective: Provide summary care record for each transition of care and referral
Measure: Provide summary of care record for at least 80 percent of transitions of care and referrals
23 – Objective: Capability to submit electronic data to immunization registries and actual submission where required and accepted
Measure: Performed at least one test of certified EHR technology’s capacity to submit electronic data to immunization registries
24 – Objective: Capability to provide electronic syndromic surveillance data to public health agencies and actual transmission according to applicable law and practice
Measure: Performed at least one test of certified EHR technology’s capacity to provide electronic syndromic surveillance data to public health agencies (unless none of the public health agencies to which an EP or eligible hospital submits such information have the capacity to receive the information electronically)
25 – Objective: Protect electronic health information maintained using certified EHR technology through the implementation of appropriate technical capabilities
Measure: Conduct or review a security risk analysis in accordance with the requirements under 45 CFR 164.308 (a)(1) and implement security updates as necessary
The Sum Total
Again, not all these criteria seem terribly relevant to chiropractic and quite frankly, I would love to see how some EMR providers can define these in such a way that they can guarantee stimulus dollars.
My recommendations:
- If you already are using EMR, approach your provider with this list and see how their system can complete the measures to obtain each objective so that you at least have a chance at getting some stimulus funding.
- If you do not yet have an EMR system, use these criteria as part of your questions to each system that you are considering for purchase, particularly if they are claiming to get you some stimulus funding. Also, consider purchasing “How to Choose a Chiropractic EMR System” Audio series to further assist you in making a wise choice of systems that will fit your needs.
- If you are unsatisfied with your current system, consider shopping for another and following the instructions in #2 – but do not purchase your new system just because you think you are going to get the HITECH dollars!
Best wishes for continued success!
Tom Necela, DC
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Your Toughest Chiropractic Billing, Coding, Documentation Questions Answered – FREE!
You are invited as a guest to Join Tom Necela, DC, CPC, CPMA — Certified Professional Coder, Certified Professional Medical Auditor, former Insurance Claims Analyst, and current President of The Strategic Chiropractor — for a special FREE 60 minute Webinar!
FREE WEBINAR!
Thursday December 17, 2009
– 9 am PST/10 am MST/11 am CST/Noon EST
So…
Bring your TOUGHEST questions on Chiropractic:
- Billing
- Coding
- Documentation
- Collections
- Getting Paid for the Work You Do!
And receive the ANSWERS you need that will help you:
- Maximize your reimbursements
- Decrease denials
- Shorten Payment delays
- Lower Accounts Receivable
- Reduce your risk of audits
We are hosting this seminar as a special “thank you” to all of our blog readers, clients and customers who have made The Strategic Chiropractor the #1 source for teaching chiropractors how to “Work SMARTER, not harder” for increased profits.
As a sign of our appreciation we’d like to offer you a FREE seat for this webinar and the chance to have your question answered “live” during the event.
(If you cannot attend or would like a CD copy of the webinar, see below for details.)
Historically, this is our most popular event webinar of the year, so you need to act quickly! Previous editions of this webinar resulted in hundreds more questions than we could physically answer in a limited time format.
Space is limited and ADVANCED REGISTRATION is MANDATORY to submit questions (the earlier you submit them, the better chance they have for being included in the presentation material). So register below, submit your questions and get your front row seat for the ultimate biggest bargain on the subject of chiropractic, billing, coding and documentation!
CLICK HERE TO REGISTER!
Hope to see you there!
Tom Necela, DC, CPC, CPMA
The Strategic Chiropractor
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Answers to Common Chiropractic Medicare Problems
In my last article on The Perennial Problem of Medicare for Chiropractors, I offered to respond to some common questions and dilemmas that you have been experiencing in regards to Medicare and your chiropractic practice. Since the blog was posted last week, we received a total of 326 responses with questions, comments, angry remarks about CMS and a few demonstrations of our collective chiropractic misunderstandings about all things Medicare.
In other words, the rumors are still out there, docs are still frustrated and problems still abound. To be fair, I did receive ONE response from a DC who was a bit perplexed about all the fanfare and indicated that Medicare was the easiest payer to deal with. Certainly, his response was the exception, not the norm. The one caution I would raise for docs who similarly feel that they are sailing along without any trouble: the RAC audits have started and they may change your opinion of the matter.
Now, let’s get to the questions! Obviously, I cannot address all 326 responses, so I have summarized the concerns into a few basic categories as follows:
Payment Denials or Downcoding. Several readers were upset that Medicare had denied or downcoded the level of service and paid them less (or not at all) as a result. More were confused about what this means. Since your adjustments are the only service Medicare pays chiropractors for, the “level” of service refers to the number of areas that you adjust and bill for – i.e. 98940, 98941 or 98942. When I perform Documentation Reviews for clients, the most common mistake I see here is that your objective findings don’t match the level of service billed. In other words, you billed a 98941 (3-4 region adjustment) but only had objective findings for perhaps 1 or 2 areas (or less). Therefore, Medicare concludes that either you didn’t meet medical necessity for the service you performed at all or that you only met medical necessity for a service that was lower (fewer areas) than the one you billed. The result: your claim will be downcoded (i.e. a 98941 will be paid at 98940 rates) or denied ( you didn’t meet medical necessity at all).
Fixing Problem Claims. This question of what to do with incorrect, incomplete, or problematic claims came in a variety of formats. Per Medicare Transmittal 1588, you can submit a corrected claim if your original claim was filed in a timely fashion and was incomplete. By incomplete, Medicare means items are missing such as NPI #, patient demographic info or other such requirements on your claim form. Incomplete does not mean that you get to re-submit your corrected claim because your original clinical documentation was substandard or missing items you should have included in the first place.
Error Rate and the Aftermath. Error rates probably mean bad news for most DC’s! Error rates are the % of claims submitted in error to Medicare that are determined to be such after a review. Error rates can result in overpayment demands (Medicare paid you, but since 20% of your claims were in error, they want a refund) or can lead to future audits (your error rate is too high, therefore Medicare will audit you again in the future to monitor your progress) or can even cause “Pre-Payment Reviews” (Medicare determines that your error rate is repeatedly too high and they will have to review your documentation prior to approving any future payments). As I said at the start, none of this is good news, although if you are receiving notices of PrePayment reviews, you definitely need help in the area of proper billing, coding and documentation.
Avoiding Medicare Patients. Some of you indicated that the only sure-fire way to avert Medicare disaster was to avoid treating Medicare patients. Certainly, you have the right to refuse to treat Medicare patients so long as you do so within the confines of your state laws. Whether this is a good tactical move may be questionable, as the Baby Boomers represent the single largest segment of the population who will be driving lots of healthcare dollars in the name of Medicare. To exclude them may represent a significant portion of your practice base. Also, be careful when you state that you do not treat any Medicare patients. By the questions some of you posed (whether hypothetical or not), you ARE treating Medicare patients but you are simply not billing Medicare for the service. If you are not doing this correctly, you could be accidentally committing fraud by doing so.
Medicare, EMR and Stimulus Funds. Several questions came in regarding integration of EMR and Medicare. According to the program, physicians (including chiropractors) will be eligible to receive stimulus funding as soon as 2011 for EMR that meets certain “meaningful use” criteria. At this point, the specific details of these requirements are still to be determined. While I am a big proponent of moving to EMR, in this respect, I agree with the ACA’s advice on the matter: “do so with the fundamental focus of improving patient care.” In other words, get the EMR because you want it to help your documentation, your clinical practices and business management – not because you may get some money from the government.
CERT Request and Audits. Apparently, there are many of you who wonder if CERT requests are an audit. CERT stands for Comprehensive Error Rate Testing and it’s likely many of you have received such a notice from Medicare. It is their way of randomly testing the accuracy of payments made. So the key word is random and is in no way an indication that you are doing things wrong (or right for that matter). Comply with the request and do not ignore it. For more detailed information on the Audit process (for both Medicare and other third party payers), types of audits and what to do I suggest you get a copy of How to Prepare Your Chiropractic Practice for Recovery Audits so you can understand what auditors are looking for and how to respond.
ABN Mysteries. ABN questions dominated my inbox in varying forms and it’s obvious there’s still a lot of confusion over ABN’s. First, by definition the ABN is an advanced notice (meaning, you have to give it to the patient beforehand not to cover your tracks afterward) that Medicare may not pay for the service you are about to render. Secondly, to simply have your patients sign an ABN each and every visit is incorrect. It presupposes that none of your chiropractic adjustments are necessary. This is not something you want to communicate to Medicare or your patient! Finally, for more detailed discussion of ABNs, let me refer you back to an older post entitled: ABN Abuse: A Common Chiropractic Practice.
FREE or Discounted Medicare Services. The “Can I include Medicare patients in my Free or Discounted…” question was posed in several ways, but the same theme is underlying. What can I give away or discount to my Medicare patients? Here is your answer. According to OIG interpretation of Section 1128a(5) of the Social Security Act, exam specials, coupons, or similar discounts should not exceed $10 individually or $50 annually per patient. So, your FREE exam or adjustment may be problematic in that it either exceeds the $10 value or that you don’t charge enough for your services. One way, you’re in trouble with Medicare; the other, your business is not likely to generate a profit if you are charging less than $10 for exams, x-rays, adjustments, etc.
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Chiropractic Billing, Coding, Documentation Seminars come to Seattle, Portland, Boise
Many of you have been emailing me regarding upcoming seminars for Fall 2009.
Here are a list of dates for Seattle, Portland and Boise:
SEATTLE, WA
- Thursday, October 22, 2009
- Saturday, November 14, 2009
River’s Edge Best Western
15901 West Valley Highway
Tukwila, WA 98188
425-226-1812
http://www.bestwesternwashington.com/hotels/best-western-rivers-edge/
PORTLAND, OR
- Saturday, October 24, 2009
- Thursday, November 12, 2009
Avalon Hotel
455 SW Hamilton Ct
503.802.5800
http://www.avalonhotelandspa.com/
BOISE, ID
- Saturday, October 31st
Cambria Suites Boise Airport
2970 West Elder Street
(208) 344-7444
Discover the latest strategies to maximize reimbursements AND reduce audit risk from Tom Necela, DC and The Strategic Chiropractor!
- New Red Flag/ Identity Theft Plan Needed by 11/2009 – get one FREE at the seminar!
- Medicare Recovery Audits started in August – are you ready?
- What you need to know about the HITECH Act of 2009, EHR stimulus hype & your compliance
- Learn Surefire Methods for Defensible Documentation
- Avoid the 4 Deadly Mistakes of EHR or computerized SOAP notes that trigger audits
- Learn ’09 Premera Blue Cross, Aetna & Cigna policy changes that affect your practice!
Also — save $$$ on taxes and get your corporation in gear with Jim Bowen’s fast paced, business & tax info that you just can’t get anywhere else!
Registration for all seminars is available online at my co-presenter Jim Bowen’s website at www.bowen.us/seminars
Hope to see you there!
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Upcoming Chiropractic Seminars: Learn the Latest Billing, Coding & Documentation Strategies
Discover the latest strategies to maximize reimbursements AND reduce audit risk from Tom Necela, DC and The Strategic Chiropractor!
- New Red Flag/ Identity Theft Plan Needed by 11/2009 – get one FREE at the seminar!
- Medicare Recovery Audits started in August – are you ready?
- What you need to know about the HITECH Act of 2009, EHR stimulus hype & your compliance
- Learn Surefire Methods for Defensible Documentation
- Avoid the 4 Deadly Mistakes of EHR or computerized SOAP notes that trigger audits
- Learn ’09 Premera Blue Cross, Aetna & Cigna policy changes that affect your practice!
SEATTLE, WA
- Thursday, October 22, 2009
- Saturday, November 14, 2009
River’s Edge Best Western
15901 West Valley Highway
Tukwila, WA 98188
425-226-1812
http://www.bestwesternwashington.com/hotels/best-western-rivers-edge/
PORTLAND, OR
- Saturday, October 24, 2009
- Thursday, November 12, 2009
Avalon Hotel
455 SW Hamilton Ct
503.802.5800
http://www.avalonhotelandspa.com/
BOISE, ID
- Saturday, October 31st
Cambria Suites Boise Airport
2970 West Elder Street
(208) 344-7444
http://www.cambriasuites.com/hotel-boise-idaho-ID042?promo=gglocal