While everyone was focused on the upcoming conversion to ICD-10 on September 30, the OIG released a new report on chiropractic titled “CMS SHOULD USE TARGETED TACTICS TO CURB QUESTIONABLE AND INAPPROPRIATE PAYMENTS FOR CHIROPRACTIC SERVICES”. This report reflected services paid in 2013.
The OIG found that a total of 7,191 chiropractors (15.8% of total chiropractors) were paid $76,104,699 in questionable payments (15.1% of the total paid to chiropractors in 2015). They identified 4 measures of questionable payments;
- Treatment suggestive of maintenance therapy
- Potential sharing of beneficiaries
- Potentially upcoded claims
- Unlikely number of services per day.
They also identified 14 individual counties with 10 or more chiropractors that received a high number of questionable payments. These include;
- Queens County, New York
- Los Angeles County, California
- Cook County, Illinois
- Kings County, New York
- Wayne County, Michigan
- Maricopa County, Arizona
- Orange County, California
- Oakland County, Michigan
- Macomb County, Michigan
- Suffolk County, New York
- San Diego County, California
- Sedgwick County, Kansas
- Du Page County, Illinois
- Nassau County, New York
In their recommendations, the OIG stated the following;
“We identified 7,191 chiropractors with questionably paid claims, 962 of whom received half of the questionable payments. In a separate memorandum, we will provide CMS with information on chiropractors with high questionable payments, so that it may take action. CMS and/or its contractors should review their claims and take appropriate action. Such actions could include: (1) recouping inappropriate payments; (2) educating providers on proper billing; (3) making referrals to law enforcement; (4) imposing payment suspensions; (5) revoking billing privileges; or (6) taking no action, if the payment is determined to be appropriate.”
If you are in the group in question, you are going to be looked at closely. Now is the time to get your Medicare house in order. To assist you in this action, I offer the following;
- Medicare three-chart reviews to determine if your documentation is correct.
- The Medicare Documentation System to help you document properly in accordance with Medicare regulations.
- Office Compliance Programs to help you be compliant with all appropriate laws, rules, and regulations.
Now is the time to take action. You can get the full report here: 2015 OIG Report on Chiropractic