by Brandy Brimhall, CPC, CMCO, CCCPC, CPCO, CPMA
October 16th, 2014
Each year the Office of Inspector General (OIG) issues an updated work plan which outlines the objectives and enforcement priorities for each new year.
For Medical providers, including Chiropractic, this information is necessary to review and be familiar with so we may evaluate our own practice systems to ensure compliance with the guidelines set forth.
The 2014 Work Plan specifically addresses Chiropractic services. To summarize this publication as it pertains to chiropractic practices, please read on:
E&M Payments (Evaluation & Management): The OIG will more closely evaluate the levels of E&M that are submitted for reimbursement to ensure that documentation requirements are met for each level of E&M billed. This objective comes with the concern of Electronic Records too easily allowing practices to duplicate codes and records. As a result, it is expected that practices of all types will be frequently over-coding (or under-coding) the E&M code that is most necessary for individual patient visits and that is most accurately supported within the documentation for individual patient visits.
Assignment Rules: The OIG plans to more closely evaluate those practices that are providing Medicare services. One objective is to review compliance of the strict guidelines in place, particularly for providers that Accept Assignment on Medicare claims. This objective comes with the speculation and supporting evidence collected by the OIG and other reviewing agencies that Medicare providers are treating and billing Medicare for services that are not 'Medically Necessary' by Medicare guidelines.
Medical Necessity and Documentation: Prior audits and research conducted by the OIG revealed payments for chiropractic services that were determined to be medically unnecessary or improperly documented (inadequate documentation to meet guidelines and/or documentation that wasn't supported with proper coding, among other findings). As a result of this, it is now listed as a priority of the OIG so they may determine the extent of such questionable billing for chiropractic services, including clearly identifying billing for maintenance therapy, which is not reimbursable by Medicare. In addition, the OIG will be examining both participating and non-participating Medicare Part B payments to verify that the claims were billed properly in accordance with Medicare rules.
While the OIG's primary focus is directed in general to government related payers such as Medicare and Medicaid, it is important to understand that this publication will impact efforts on behalf of other types of carriers as well. The OIG Work Plan is a foundation and guide used for all carrier types. In other words, audit and recovery efforts for both pre and post-payment claims are expected to increase as we progress through this year.
Click the following link if you would like to review the entire OIG Work Plan for 2014.
WHAT SHOULD YOU DO TO PROTECT YOUR PRACTICE?
In effort to best prepare for potential records reviews and audits within your practice, the best thing to do is to educate both doctors and staff and be proactive in the steps that are taken to implement proper and required protocol for coding, documentation and for other compliance related issues.
A few immediate steps that can be taken:
1. Conduct a Gap Analysis of the coding/billing and documentation portion of your practice.
This consists of a complete review of the following:
• Documentation guidelines to be met in comparison to a sampling of documentation currently taken
• Review of current codes used (CPT/HCPCS, ICD-9) in comparison to the complete code definitions found in current year coding manuals (Yes, those from previous years are too old!)
• Evaluation of fees
• Review of payer policies and Medicare LCDs as applicable
• Evaluation of billing, data entry and accounts receivable systems
In performing a Gap Analysis, you are essentially looking for "gaps" and are able to find and fix these internally as opposed to waiting for them to be discovered in an audit only to become much more costly and stressful. For more specific steps to conduct your own Gap Analysis, please request your free step-by-step instructional guide to help with this essential step.
2. Scheduled Training: Will allow for unity with your team and improve communication as yet another step to avoid or minimize errors.
Training sessions should include, at a minimum:
• A review of complete code definitions including CPT, HCPCS and ICD-9,
• Assistance with documentation guideline for E/M services as well as other procedures
• Review systems for data entry
• Q/A for documentation systems, coding, data entry, billing and collections.
It is of utmost importance that doctors and staff are on the same page. Like a football team practicing to execute plays as seamlessly as possible, the chiropractic "team" must also continue to address fundamentals and continue to review and evaluate systems in effort to avoid or minimize unnecessary oversights and mistakes.
3. Implement policy in your practice to increase and improve communication between doctors and staff. It is important to address issues in a timely manner and to avoid making assumptions or guesses when uncertain.
4. Ask for help. It can be difficult to find answers or even to find the time to collect information needed to properly execute essential and protective measures for your practice. Rather than waiting until you find time or guessing because you aren't sure, reach out to those with expertise in these areas to get the information and the help you need.
The suggestions that I have listed for you just above are a mere starting point for every practice but a very necessary one that cannot be overlooked or set aside. If you would like assistance with your own Gap Analysis, help conducting training or even organizing your training schedule; contact the ChiroCode Institute for help. We stand ready to serve you!