The OIG’s most recent report on fraud in the chiropractic community identifies seven states that make up more than half of the inappropriate Medicare chiropractic payments: California, Michigan, Illinois, New York, Kansas, Florida, and New Jersey. Each of these states have more than 50 chiropractors with questionable billing and payment practices.
In Illinois the Medicare Strike Force is active in both DuPage and Cook counties where 40 chiropractors meet these criteria. While they didn’t publish any names in the report, they did indicate some of the elements they are watching.
Some of the practices that have the OIG’s attention include:
- Multidisciplinary practices with unusual utilization
- Chiropractic, occupational therapy and/or physical therapy visits billed on the same date
- High volumes of 98942 billing
- Maintenance therapy billed as active care
- High volume practices
One Illinois practice has been singled out for averaging 88 Medicare visits a day for at least 115 days!
Nationwide the OIG has identified 962 chiropractors with highly questionable practices and finds that these same providers have been substantially increasing their claims volumes each year and show a questionable payment pattern for at least 5 years. On average, chiropractors with high questionable payments provided services to twice the number of beneficiaries and file four times the claims compared to all other chiropractors.
The OIG acknowledges in its report that 84% of DC’s nationwide have no questionable payment patterns. The remaining 16% have questionable patterns with 2%, or 962 of these physicians receiving more than 50% of the inappropriate payments.
The report makes several suggestions for changes at CMS: tightening software denials when inappropriate diagnoses codes are used, collecting overpayments and taking “appropriate” action against those highly questionable practices are among the recommendations.
While this report is focused on Medicare beneficiaries, the same rules may apply to commercial carriers. What should you do?
Review your billing and documentation.
- If you consistently bill more than 10% of your patients with a 98942, get your records reviewed to see if the visits meet the medical necessity and daily visit criteria.
- If you are unsure of when to switch your patients to a maintenance program, seek assistance!
- If you are part of a multidisciplinary practice, make sure you are appropriately utilizing providers. Patient’s treating with more than 1 provider per visit can raise a red flag.
There are many resources available to chiropractors. Check out www.cstonemedical.com, www.chirocode.com, www.chirohealthusa.com, and www.chiromedicare.net are just a few of the sites with resources and consulting services to assist you.