Because compliance covers so many areas of a healthcare provider practice, a more thorough explanation is found in Chapter 3-Compliance in the ChiroCode DeskBook. Generally, healthcare providers need to understand:
For additional information visit ChiroCode.com. Since 1993 Chiropractors have depended on ChiroCode as a reliable source of information for the Chiropractic community. Because of the dependability and education ChiroCode has earned much renown. View current and recent webinars, order the ChiroCode DeskBook, (comprehensive go-to chiropractic reimbursement manual) and much more.
Select the title to see a summary and a link to the full article.
October 7th, 2020
Stay out of Trouble — Understand the Qualified Medicare Beneficiary (QMB) Program
By Wyn Staheli, Director of Research | Published October 7th, 2020
To assist low-income Medicare beneficiaries, CMS created the Qualified Medicare Beneficiary (QMB) program; a Medicaid benefit which pays for Medicare deductibles, coinsurance, or copays for any Medicare-covered items and services for Medicare Part A, Part B, and Medicare Advantage (Part C). Providers/suppliers are prohibited from billing premiums and cost sharing to Medicare beneficiaries who are enrolled in QMB.
By Wyn Staheli, Director of Research | Published March 25th, 2020
Your inbox is probably like mine with all sorts of announcements about COVID-19. Here are just a few reminders of things we felt should be passed along.
We have heard of several cases of cybercrime related to this outbreak. For example, there was a coronavirus map which loads malware onto your ...
The OIG Work Plan: What Is It and Why Should I Care?
By Namas | Published August 9th, 2019 - Last Review/Update August 14th, 2019
The Department of Health and Human Services (HHS) founded its Office of Inspector General (OIG) in 1976 and tasked it with the responsibility to combat waste, fraud, and abuse within Medicare, Medicaid, and the other HHS programs. With approximately 1,600 employees, HHS OIG is the largest inspector general's office within ...
Q/A: Can I Put the DC’s NPI in Item Number 24J for Massage Services?
By Wyn Staheli, Director of Research | Published July 8th, 2019
Question:
Are there scenarios in which it is acceptable to put the DC's NPI in box 24j for massage services?
Answer:
While the answer to this is yes, it is essential to understand that there are very limited scenarios. In most cases, Item Number 24J is only for the NPI of the individual ...
Rules for Rendering Unproven, Investigational or Experimental Procedures
By Brandy Brimhall, CPC, CMCO, CCCPC, CPCO, CPMA | Published July 1st, 2019
If you haven’t reviewed your state guidelines or taken a recent look at third-party payer policies on unproven, investigational or experimental procedures, now is the perfect time to make sure you’re up to speed with this important information. Most providers are surprised to see commonly used devices or techniques listed ...
Q/A: Can I Refuse to File a Patient's Medical Insurance for an Auto Accident?
By Wyn Staheli, Director of Research | Published June 25th, 2019
Question:
Can a Chiropractor refuse to file a patients Medical Insurance for an Auto Accident?
Answer:
There isn't a simple answer to this question. It depends on who is responsible and state laws. Who is responsible (the auto insurance or the medical insurance) can depend on state requirements as well as who is ...
Q/A: I’m Being Audited? Is There a Documentation Template I can use?
By Wyn Staheli, Director of Research | Published April 29th, 2019
Question: Our Medicare contractor is auditing claims with 98942. Do you have any suggestions for a template for documentation to warrant the use of 98942?
Answer: When you submit a claim with code 98942 you are stating that you have determined that it was medically necessary to adjust all 5 of ...
By Dr. Ray Foxworth, MCS-P, President of ChiroHealthUSA | Published November 28th, 2018 - Last Review/Update January 21st, 2019
You simply need to read the headlines, posts, and tweets, about providers across the healthcare profession being audited, fined, and some even convicted, to see that the costs of non-compliance are real. We tell ourselves, “It won’t happen to me.” The reality is that it easily could. Your license is your livelihood.
Q/A: Does My LMT need an NPI? How do I Bill Her Services?
By Wyn Staheli, Director of Research | Published October 22nd, 2018 - Last Review/Update December 19th, 2018
Question:
I am setting up an LMT to work as employee under Dr. Clifton, DC. i need to know several things - hoping they are related and can be grouped into this one question.... does she need her own NPI? where does that NPI # go? what box #? if not, ...
Q/A: Can a PT Assistant Perform Physical Therapy Modalities?
By Wyn Staheli, Director of Research | Published June 18th, 2018 - Last Review/Update January 30th, 2019
Whether or not a physical therapy assistant (PTA) may perform physical therapy modalities depends on two factors: state law and payer policies. Read here for more.
By Wyn Staheli, Director of Research | Published April 30th, 2018 - Last Review/Update January 30th, 2019
As chiropractors we feel the new modifier 97 is more appropriate than 96 for our PT codes such as stim and traction. Yet Carefirst is asking for 96 only. Should we use this code on all the PT codes and for all the other insurance companies?
By Brandy Brimhall, CPC CPCO CMCO CPMA QCC | Published October 13th, 2017 - Last Review/Update February 5th, 2019
Chiropractors cannot opt-opt of Medicare. Does that only refer to chiropractors that see Medicare patients? Do all Florida chiropractors have to complete Medicare enrollment/credentialing? Bottom line- do ALL chiropractors, no matter where or who, have to complete Medicare enrollment since they cannot Opt-out?
By Wyn Staheli, Director of Research | Published February 23rd, 2017
In June 2015, the Office of Inspector General (OIG) issued a Fraud Alert focused on physicians and compensation arrangements. Providers need to ensure that these arrangements do not violate the Anti-Kickback Statute. Healthcare providers found to have committed fraud are subject to possible criminal, civil and administrative sanctions.
In this alert ...
Mastering Medicare: When Opting Out is not an Option
By Dr. Ray Foxworth, Certified Medical Compliance Specialist and President of ChiroHealthUSA | Published June 15th, 2016 - Last Review/Update March 5th, 2019
Unlike MDs and DOs, chiropractors may not opt out of Medicare.
When it comes to Medicare, providers and patients alike feel like beating their heads against the wall. Signing up to be a provider or a patient is confusing, understanding what is covered is confusing and just about the time you think you have it figured out, you receive a notice that suggests you don’t.
The hassles of Medicare certainly validate any sane person questioning whether they should see a Medicare patient, but with the rising number of Medicare patients in the US do you really want to limit your patient base?
By Dr. Ray Foxworth, Certified Medical Compliance Specialist and President of ChiroHealthUSA | Published May 26th, 2016 - Last Review/Update March 5th, 2019
Our team is frequently asked if it is legal for chiropractic offices to offer coupons or Groupons. We’re not allowed, as a profession, to dramatically discount our services, offer free treatments, or provide gifts or free meals for potential patients. Any one of these things can be considered an “inducement.” Practices that improperly induce patients to seek care or services, for example, by providing coupons for care or supplies, may find that they are in violation of the law if they aren’t careful.
So what will that mean to you and your practice? It isn’t pretty.
Your Reasons to Delay Compliance Implementation are GONE!
By Brandy Brimhall, CPC, CMCO, CCCPC, CPCO, CPMA | Published May 19th, 2016
ChiroCode has proudly served chiropractic for more than 30 years and continues to work to bring the most necessary, affordable, and user friendly products and services to practices. Increased regulation has hindered practices by creating uncertainty around the nature of guidelines and the expensive penalties that arise from non-compliance with ...
Lack of Business Associate Agreement (BAA) Costs Non-Profit 1.55 Million
By Wyn Staheli, Director of Research | Published April 13th, 2016
Failure to have a properly executed Business Associate Agreements (BAA) costs one organization $1.55 Million. In today's highly technological environment, it is too easy to skip the necessary precautions and easy for electronic devices to get lost or stolen. Are you prepared?
By Instacode Institute | Published April 6th, 2016
It's not just the names and addresses that matter -- It's the compliance. If you can demonstrate that you are hleping yourself to maintain HIPAA compliance by careful documentation and proper procedures, you can go a long way toward avoiding being fined by the HIPAA squads.
Complete & Easy HIPAA Compliance is a clear, simple “Just help me do what I have to do!” workbook that contains all the things the designated security officer must do to instantiate a robust HIPAA compliance program. It comes complete with over 45 forms and letters which can be used to state the office policies, spell out procedures, and ensure that each patient will be protected in their rights under HIPAA policy. It also can help demonstrate that a compliance program is in progress.
Occasionally providers are faced with the need to assess the option of making a voluntary disclosure to the government. Here are steps that every provider should consider before disclosing information to the government.
Protected Health Information De-Identification Standards
By Instacode Institute | Published March 16th, 2016 - Last Review/Update January 27th, 2017
This article contains detailed information on the OCR guidance regarding the de-identification of Protected Health Information (PHI). Avoid HIPAA violations and learn specifically what de-identification is.
Employee Exclusions Screenings Must be High Priority
By Wyn Staheli | Published February 24th, 2016
Many healthcare organizations are not aware of how critically important it is to screen their employees against ALL state and federal exclusions databases. This article has important information for organization to ensure compliance.
Chiropractic Listed as Focal Point in 2015 OIG Work Plan
By Brandy Brimhall, CPC, CMCO, CCCPC, CPCO, CPMA | Published August 19th, 2015 - Last Review/Update January 30th, 2017
With the recent release of the 2015 OIG Work Plan, many providers and facilities are reviewing the content to learn which areas of interest pertaining to their specialty will be points of interest for federal auditing programs for the 2015 Fiscal Year. The information contained in this Work Plan addresses the ...
By ChiroCode | Published August 10th, 2015 - Last Review/Update January 27th, 2017
The following are some of the acronyms you would need to know when communicating with auditors:
National Correct Coding Initiative (NCCI) Edits: Use of codes that should not occur on the same day, effectively treating the same area twice.
Medically Unlikely Edits (MUE): Exceeding the anticipated units of service (time spent) for a given HCPCS or CPT code.
Office of the ...
By Dr. Chris Andersn | Published April 24th, 2015 - Last Review/Update June 9th, 2016
Compliance is an issue that you should look at as an expedition rather than an endpoint. Board complaints can be a terrifying ordeal, especially if you don’t keep up on compliance in your clinic. Board complaints are something that you have to expect to happen but you can turn that ...
Chiropractic Listed as Focal Point in 2015 OIG Work Plan
By | Published January 23rd, 2015 - Last Review/Update January 30th, 2017
With the recent release of the 2015 OIG Work Plan, many providers and facilities are reviewing the content to learn which areas of interest pertaining to their specialty will be points of interest for federal auditing programs for the 2015 Fiscal Year. The information contained in this Work Plan addresses ...
By | Published December 30th, 2014 - Last Review/Update March 9th, 2016
Time-of-Service (TOS) discounts are a common occurrence in chiropractic. What is often assumed is that if insurance isn't involved, there are no rules that apply.
Unfortunately, this is a myth that can become costly to practices and damage provider/patient relationships. So read on to learn the facts about TOS discounting and ...
OIG Reports Success in Efforts to Prevent Fraud, Waste, and Abuse
By | Published December 15th, 2014 - Last Review/Update January 30th, 2017
The HHS OIG Work Plan for the 2015 Fiscal Year has recently been released. In this publication, the OIG addresses the accomplishments made from the previous year's Plan as well as the objectives that will be of interest for the coming new year. Accomplishments for the 2014 Fiscal Year are ...
Establishing a Multi-Disciplinary Practice and Being Legal
By Brandy Brimhall, CPC, CMCO, CCCPC, CPCO, CPMA | Published November 21st, 2014 - Last Review/Update January 30th, 2017
Q: How do you add another provider type such as a Nurse Practitioner to your practice to provide additional services to patients and legally bill for those services under their license?
A: Multi-disciplinary practices are under scrutiny at the moment by ZPIC, CMS and State Boards. For your reference, just below, there ...
By Brandy Brimhall, CPC, CMCO, CCCPC, CPCO, CPMA | Published November 19th, 2014 - Last Review/Update January 30th, 2017
Recovery Audit Contractors, also known as RAC, is a program that seeks to identify and correct improper payments for services provided to Medicare Parts A & B beneficiaries. This includes both recoupment of overpayments and corrected distribution of underpayments made by CMS.  RAC began in 2005 as a three-year demonstration project consisting ...
Conducting a Gap Analysis for Your Documentation & Billing Systems
By Brandy Brimhall, CPC, CMCO, CCCPC, CPCO, CPMA | Published November 17th, 2014 - Last Review/Update January 30th, 2017
What is a Gap Analysis?
A Gap Analysis is a process by which a practice conducts a baseline assessment of the company's coding, billing, operations, and business practices. The objective of a Gap Analysis is to ensure that the practice is in full compliance with applicable legal and ethical requirements. This ...
By Evan M. Gwilliam DC MBA BS CPC CCPC QCC CPC-I MCS-P CPMA CMHP | Published October 24th, 2014 - Last Review/Update January 30th, 2017
Straight from the Office of Civil Rights:
Q: Does the HIPAA Privacy Rule permit health care providers to use e-mail to discuss health issues and treatment with their patients?
A: Yes. The Privacy Rule allows covered health care providers to communicate electronically, such as through e-mail, with their patients, provided they apply ...
By Evan M. Gwilliam DC MBA BS CPC CCPC QCC CPC-I MCS-P CPMA CMHP | Published October 16th, 2014 - Last Review/Update January 23rd, 2017
In October of 2000 in the Federal Register the Office of the Inspector General (who investigates fraud against the federal government on behalf of the Department of Health and Human Services) offered general guidelines for health care facilities to set up a “Compliance Program”. This advice has long been pushed ...
By | Published October 3rd, 2014 - Last Review/Update January 27th, 2017
A “good” lawyer could be a “bad” lawyer when it come to your unique problem(s). Never ask or expect any professional person (doctor or lawyer) to perform beyond their scope of practice or ability. A college law degree and passing the state bar, is only a license which permits them ...
By Christine Woolstenhulme, QCC, QMCS, CPC, CMRS | Published September 26th, 2014 - Last Review/Update January 30th, 2017
MEASURE COMPLIANCE - Meeting the Patient Electronic Access Objective
Starting in 2014, CMS requires that providers participating in both Stage 1 and Stage 2 of the EHR Incentive Programs must meet the Patient Electronic Access objective, which gives patients access to their health information in a timely manner. Providers participating in ...
According to HIPAA, who are my Business Associates?
By Brandy Brimhall, CPC, CMCO, CCCPC, CPCO, CPMA | Published September 11th, 2014 - Last Review/Update January 30th, 2017
Providers work with many different groups and many of them have some interaction with Protected Health Information (PHI). In an effort to help us understand who qualifies as Business Associates the Department of Health & Human Services has provided some resources.
But first … what is PHI or individually identifiable health information? ...
By | Published February 19th, 2014 - Last Review/Update January 27th, 2017
As more and more people are using mobile and wireless devices, a new buzzword has emerged: mHealth. According to a National Institute of Health consensus group, mHealth is "the use of mobile and wireless devices to improve health outcomes, healthcare services and health research." Historically, the biggest gaps and HIPAA violations ...
By | Published September 30th, 2013 - Last Review/Update January 27th, 2017
September 23rd, 2013 was the deadline for HIPAA Omnibus Final Rule compliance. It seems to have just snuck up on everybody. ChiroCode has spoken with some clincis who say that they don't need to worry about it because ”they are just a small practice.” Please, do not wait any longer to ...
By | Published September 24th, 2013 - Last Review/Update January 27th, 2017
Be aware of the possible monetary results and enforcement actions imposed for fraud. This is the annual report of the Department of Justice Health Care Fraud and Abuse Control Program for FY 2012
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