Many chiropractors and other physicians around the country will be receiving audit letters as part of President Obama's Executive Order # 13520, "Reducing Improper Payments and Eliminating Waste in Federal Programs." In an attempt to eliminate payment errors, waste, fraud, and abuse in Federal programs such as Medicare, this executuve order requires federal agencies to investigate areas where potential problems may exist.
As a result, beginning August 2010, Medicare will be reviewing claims of chiropractors and other physicians for errors. For chiropractic physicians, the affected group will be doctors of chiropractic who submitted multiple claims for the same Medicare patient with service dates between April 2010 and June 2010.
Medicare will randomly sample chiropractors who fit this profile and will determine whether chiropractic services were billed correctly as meets the definition of medical necessity. In the context of these reviews, the audit may investigate up to 12 months prior to the date of service on the claim. CMS will deny claims for services determined to be not medically necessary and, if needed, take appropriate steps to recoup any overpayments.
"The most important thing to do when receiving a letter from the CERT Documentation Contractor is to comply with the audit records request." states Dr. Tom Necela, a chiropractor, Professional Coder and Certified Professional Medical Auditor. Necela's consulting firm, The Strategic Chiropractor, handles audit requests for many chiropractors and he notes that "some chiropractors are afraid of submitting imperfect records out of the fear that their services will be denied." Necela cautions that "This reaction almost always makes the problem worse because the failure to respond to a record request will not only result in a denial, but may also result in the provider being charged with fraud."
Physicians who receive a CERT letter have 30 days to comply with the audit request. Regardless of any possible documentation shortcomings,Dr. Necela recommends that providers submit their documentation immediately after receiving the request to avoid further penalties. Dr Necela advises "The final step is to fix any problems noted as a result of the audit to prevent future problems!"
Tom Necela, DC, CPC, CPMA is the President of The Strategic Chiropractor, a consulting firm dedicated to helping chiropractors maximize reimbursements and minimize their risk of audits by teaching sound billing, coding, documentation and collections strategies. If you'd like more information about Dr. Necela's consulting programs (which include a Documentation Self-Audit), go to http://www.strategicdc.com
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