In case you were really hankering for some bad news from Medicare, here’s a couple gems that hit directly at the chiropractic profession.
Perhaps you have been following the trail of the Medicare fee increase or maybe you have better things to do in between adjustments than watch a complete demonstration of Medicare insanity. Either way, you will be pleased to know that:
“in anticipation of the vote to increase Medicare fees in 2010 by 2.2% and in 2011 by 1% which was in response to the previous defeat of the bill to decrease Medicare fee schedule by 21%, Medicare has reported that they will continue to hold claims through Thursday June 17th. If Congress has not taken final action by Friday June 18th, claims will be paid with the 21% fee decrease applied.”
And if you can read that quote, you probably either have a law degree or spend too much time reading plot-twisting Tom Clancy novels not actually written by Tom Clancy!
To summarize: Medicare may not quite know what it’s doing with the fee schedule fiasco yet and they plan to hold your claims until June 17, 2010 — in other words, not pay you anything. After that point, they may pay based on the 21% fee decrease, IF no further action is taken….
Not surprisingly, I have received many emails full of confusion and conflict over this issue from chiropractors around the country. I have been repeatedly informed of carriers who have already been processing claims with a small fee decrease since January 1 – not the proposed 21% decrease, nor the 0% “interim” fee increase from the 2009 fee schedule that is supposed to be in effect until Medicare gets its act together and a resolution has been obtained. Others have written in to state that Medicare has been paying exactly as expected. Still other more valiant chiropractic efforts have been reported by offices who have attempted to call their Medicare carrier and ask for an explanation of why, when and how they are to be paid. The responses have ranged from ridiculous to right on the money.
(Interesting side note: I even have a couple Medicare carriers following ME on my Twitter page. Isn’t that supposed to be the other way around?! Perhaps just everyone is desperate for info on the subject matter, even Mr. Medicare himself.)
Obviously, there is still a lot of confusion over the details of the proposed Medicare fee schedules (from both the payers and the providers) and a lot of anger. Witness the recent move by the MD’s represented by the AMA who turned in their lab coats as a sign of protest over Medicare’s move.
One thing emerges as a clear action step: DC’s really need to watch reimbursements to determine exactly how you are being paid. Then compare that to how you should be paid. Hopefully they match. If not, my suspicion is that Medicare will be getting more calls and appeals than usual this year.
More Medicare Mess
In other news, Medicare carrier Palmetto GBA released its Medical Review findings for the 2nd Quarter (yes, I know for most of the world, the 2nd quarter hasn’t finished yet – see they’re not behind on EVERYTHING!).
While these findings are specific to this carrier, I believe that they are indicative of challenges the chiropractic profession faces at large, so I will report them here. Of the 12 items listed that reflect “the majority of documentation issues discovered during the review process” there are four that affect chiropractic in general, and one is specific to chiropractic services exclusively.
Here are the common errors (with my comments in italics below) that were found so that you can be sure to avoid them in your own practice, as I am certain your carrier is finding similar problems:
Signatures: Documentation missing signature authentication by the author of the electronic medical record or contains an illegible signature.
(This is an easy mistake to fix and too simple to get nailed on. See Medicare signature requirements so you don’t kick yourself for getting claim denials over your signature.)
Evaluation and Management Services: Services do not meet the minimum documentation requirements.
? Specific concerns:
- Use of ‘noncontributory’
- Documenting ‘labs reviewed’ without further information
- Referred to documentation that was not included with medical review request
- Ancillary staff or scribe documentation requirements were not met, and
- Counseling/coordination of care missing time and/or documentation to support service
(While Medicare doesn’t pay DC’s for E/M codes, other insurance companies do. From my experience looking at chiropractor’s documentation, many of the errors above are routinely made on many regular insurance claims.)
Legibility: We accept transcribed notes in addition to copies of originals.
(In other words, if you are not on EMR and your handwriting is pitiful enough that it cannot be read by the average person with no special eyesight abilities, use a transcription service to type up your chicken scratch so at least someone can read them.)
No response to request for medical records: Often times this is because a provider failed to update his/her address/phone number; therefore we are unable to locate the provider. Please keep in mind it is the provider’s responsibility to notify Palmetto GBA within 90 days of any changes that occur. Please follow all instructions provided on any letter requesting documentation.
(These instructions are for Palmetto, but most – if not all – carriers have a similar policy. From experience, I can tell you that nearly every DC that has ever moved a practice incurs a lag time before Medicare catches up. In the past, this was just inconvenient. Presently, if you happen to receive a negative determination or payment demand and fail to respond – due to the fact that you moved or for ANY reason – you need to respond PROMPTLY or you will pay the price…literally.)
Chiropractic Services: Missing treatment plan with specific objective, measurable treatment goals. Follow thru with these specific objective treatment goals on subsequent visits is often omitted. The initial visit and subsequent visit often was missing key elements/requirements outlined in the Internet-Only Manual Medicare Claims Processing Manual 100-04, Chapter 12, section 220. Reminder: Subluxation may be established by either an x-ray or hands-on examination (P.A.R.T.)
(In other determination and reviews I have seen, the terminology “missing” is actually different than “incomplete.” While that may sound obvious to you, consider what this carrier is saying: DC’s are not including ANY treatment plan as a part of their notes. It’s not inadequate, incomplete or subpar – it’s just not there!! Obviously, if there is no treatment plan, there will be no measurable treatment goals. Heck no goals at all!)
See you next week – where hopefully there won’t be more bad Medicare news to report!
Tom Necela, DC, CPC, CPMA
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