OIG Says, Get with the Program!
Written by Editor   
Thursday, March 01, 2018 09:33 AM

Guest Contributors Kelli Moore, MCS-PI and Amanda Myers, MCS-P 
with The Collection Coach

Chiropractors are no strangers to overcoming adversity. Across decades and around the globe, chiropractors have fought for-and won-recognition as experts of the musculoskeletal system. It has been proven time and time again that chiropractic treatments are safe, effective, and can have life-changing, long-lasting gains for patients. No wonder, then, that when the Social Security Act (Medicare) was first passed in 1965 without offering coverage for chiropractic services, patients worked together with their doctors to demand change of their legislative advocates.

Seven years of hard work paid off, when coverage of spinal manipulation by a chiropractor was included in an amendment of the Act-with no set visit limits. Over the next two years, legislation was passed to prevent discrimination from insurance payers, and by the end of 1974 it was fully reimbursable and protected in all 50 states; a huge milestone for the field.

Sadly, some today would quickly throw all that hard work away, citing the difficulty of working with insurance carriers. With limitations on coverage, requests for records, contractual discounts, and prior authorization, it is understandable that so many providers are frustrated. 

Providers are not the only ones feeling the frustration. The Office of Inspector General’s (OIG) February 2018 portfolio entitled Medicare Needs Better Control to Prevent Fraud, Watse and Abuse Related to Chiropractic Services states, “claims for chiropractic services were typically denied because the services were medically unnecessary, billed with an incorrect procedure code, not documented, or insufficiently documented.” Publications by the OIG going as far back as August 1986 have stressed this same sentiment: chiropractic documentation is not good enough to justify payment after the twelfth visit. The newest complaint leveled against chiropractic by the OIG is that when chiropractic care is denied as not medically necessary because it was “deemed to be maintenance care”, it is now “harmful” to the beneficiary. Other reports have chiropractic with a 54.1 percent claims error rate, “the highest among all Part B providers”.

Granted, Medicare fraud, waste, and abuse are not issues that trouble the field of Chiropractic alone. This problem is prevalent across all provider types. The OIG disclosed that in 2010 Medicare inappropriately paid $6.7 billion to medical providers for E/M services that were incorrectly coded and/or lacking documentation, at a calculated 55% error rate! The same report noted, that in 2006 medical providers had a 75% error rate for consultation services, a type of E/M service. In response, by 2010 reimbursement for consultation services was discontinued.

From the start, chiropractors and their patients have fought for parity in the medical field. We want to be recognized by CMS with equal monetary compensation for our time and expertise when performing all services such as x-rays, therapies, and E/M services. Many feel this is a fair request. But consider this, chiropractors have the highest error rate among Part B providers, and we only have three codes CMS covers. How much sense does it make for CMS to expand the chiropractic scope to include E/M services – which have equally high error rates amongst covered provider types?

If chiropractic is ever to get that parity, then the entirety of our field needs to step up to the challenge of getting our documentation and billing correct. The worst thing a chiropractor can do at this moment in time is: continuing along without heeding the documentation requirements of CMS. Remember that coverage of consultation services was completely discontinued after providers’ error rates climbed too high.

As chiropractic professionals, you have the right to choose whether you wish to treat Medicare patients or not. But if you choose to take Medicare, get with the program! Learn the documentation requirements. It’s not hard, Medicare publishes exactly what to document to prove medical necessity and pass every audit.

Contact Kelli and Amanda at TheCollectionCoach.com .