Medicare Releases Chiropractic’s Comparative Billing Report Pilot

Written by Tom Necela, DC, CPC, CPMA, CCP-P on October 14th, 2010

Topics: Audits, Chiropractic Audits, Medicare

Doctors, your “report card” is now available.

This past week (10/4/2010), chiropractors in the state of Wisconsin were the “pilot” program subjects who began receiving a “Comparative Billing Report” (CBR) produced by SafeGuard Services who is under contract by Medicare (CMS).

Don’t worry Wisconsin DC’s, they’re not just picking on you — the national release of the CBR is anticipated to be be sent three weeks later to 5000 chiropractors nationwide.

The focus of the CBR is on the average number of services per Medicare beneficiary (your patient) and the top 5 diagnosis codes billed compared to the individual chiropractor’s state and the nation. The CBRs will eventually be released to approximately 5,000 DC’s.

The CBRs provide comparative data on how an individual health care provider compares to other providers by looking at utilization patterns for services, beneficiaries, and diagnoses billed. Apparently, Medicare has received feedback that this kind of data is very helpful to providers.

The good news is that these reports are not available to anyone but the provider who receives them. To ensure privacy, CMS presents only summary billing information. No patient or case-specific data is included. These reports are tools to help providers comply with Medicare billing rules and improve the level of care they furnish to their Medicare patients.

The purpose of this Comparative Billing Report (CBR) is to inform Chiropractic providers and help prevent improper payments. The analysis for this CBR encompassed all Medicare chiropractor claims data with (1) service dates from January 1, 2009 through December 31, 2009 that are processed by July 2010, (2) “office” as the place of service, and (3) CPT codes equal to 98940 (chiropractic manipulative treatment [CMT]; spinal, 1-2 regions), 98941 (CMT; spinal, 3-4 regions), and 98942 (CMT; spinal, 5 regions).

The utilization measures that are analyzed in this CBR for all three CPT codes are:

(1) the average number of services you billed per beneficiary and

(2) the number of beneficiaries by three categories defined by the number of distinct diagnoses.

These measures were statistically compared to the average of your state and national peers and the results are displayed in graphs and tables. In addition, this CBR will identify the top five diagnoses of the beneficiaries you billed, along with those of your state and national peers.

The CBR is not intended to be punitive or sent as an indication of fraud. Rather it is intended to be a proactive statement that will help the provider identify potential errors in their billing practice. A CBR contains peer comparisons which can be used to provide helpful insights into their coding and billing practices. The information provided is designed to help the provider prevent improper billing and payment.

What to Do Next:

If you receive a CBR, it will give you specific details on how you compare. This is a rare opportunity to review our potential problems or shortcomings without punishment. We must capitalize on this and learn all we can.
Look for graphical illustrations of where you may be considered an “outlier” or have statistically significant differences than your peers. If the bar on your graph is too far away from everyone else, consider your billing or coding patterns and get help before it’s too late.
If you do not receive a CBP, consider yourself fortunate and look at an example anyway. Review a sample of the chiropractic CBR at the link above.
Get a Preventative Audit. Many don’t like that term, so I prefer to call them a Documentation Review. For those who like in far corners of the earth, can’t bear to leave the office, or get a sudden onset of ADD when they sit in a seminar, this may be a good option for you. Essentially, you submit your notes (along with your billing and coding) and I will scrutinize them with a fine-toothed comb making sure that your services are properly documented and that you used the appropriate CPT code and bill the services performed. Following my review of your notes, you will review a painstakingly (and perhaps, painfully) detailed written review of your shortcomings and areas needing improvement according to published guidelines and my experience as a former Insurance Claims Analyst and my training as a Certified Professional coder and Certified Professional Medical Auditor. For more specifics on the Documentation Review process and fees, send an email to info@strategicdc.com.