I Didn’t Learn That in School!
DOCUMENTATION
Kathy Mills Chang
When you were in chiropractic college, did you miss that class on documenting for medical necessity? How about that coursework on coding for maximum reimbursement? How about anything to do with how to run your business in this highly regulated healthcare environment?
That would be because little was probably offered, if any. Chiropractic schools turn out some of the very best doctors in the country, healers who excel at holistic care, thorough examinations, and treatment plans with great outcomes. However, because time limits curricula, chiropractic education understandably focuses on anatomy, techniques, diagnosis, and treatment. The unfortunate but unavoidable consequence is that most chiropractors never learn about advanced documentation, Medicare, compliance, and the business side of running a practice, which leaves them stranded and confused for the simple reason that no one had the time to teach them about it.
In an ideal world, no one would open a shiny new chiropractic business without first understanding what he or she is up against with the laws, regulations, billing rules, and other systems necessary to run the business. When I started my business, for example, I knew just enough about accounting to be dangerous. I certainly didn’t know everything I would
^ In an ideal world, no one would open a shiny new chiropractic business without first understanding what he or she is up against with the laws, regulations, billing rules, and other systems necessary to run the business. J J
have needed to know about bookkeeping, tax filings, and employee recordkeeping. Rather than simply flinging my door open for business and assuming I’d figure it out later, I surrounded myself with subject-matter experts on my virtual
“board of directors. ”
I have a bookkeeping specialist who manages that aspect of my business, an attorney for on-demand legal advice, and an accountant for on-demand accounting and tax advice. In addition, I’m worry-free because I don’t have to keep up on all of the rules and regulations in these highly volatile and critical areas of business. I know who to go to, and who will keep me up to speed and out of trouble.
Clearly, chiropractors need and deserve subject-matter experts, too. For example, every third-party payer contract states that doctors must meet all of the medical review policy requirements for the services that they bill, and yet most chiropractic offices have never even looked at the contract in the first place. Third-party payers really don’t care how busy you are, or how well intentioned you may be. They quite simply expect you to know this stuff, and they aren’t particularly forgiving when you don’t.
That’s why it seems many doctors come to us under one of three circumstances: 1) they find themselves in the middle of an audit; 2) they know someone else who’s in the middle of an audit; or 3) they’re worried that they are going to be audited. With records requests and subsequent audits on the rise, they’re right to be concerned.
^Documentation issues, paperwork piles, Medicare rules and regulations, and proper coding are all integral to running a safe and successful practice.
Just as chiropractors themselves wouldn’t launch into treatment without evaluating the patient, the first thing chiropractors should do here is evaluate the practice’s current documentation. Here are just a few of the typical things often found to be in error:
• A pattern of down-coding
Some doctors believe they can fly below an auditor’s radar by undercoding, but you can get in just as much trouble for underreporting the actual treatment you provided as you can for fudging in the other direction.
• A pattern of up-coding
Maybe some doctors really do treat all five regions at every visit, but we have yet to see it properly documented and billed. Sadly, some doctors do this out of ignorance rather than greed. Auditors, however, don’t care about your motivation and will be on you faster than you can say “recoupment.”
• A pattern of coding, period
Auditors don’t like to see any repetitive coding pattern. It leads them to believe that you’re either providing assembly-line treatment and not paying attention to the specific needs of patients, or that you have no idea how to code what you do, so you just use the same codes repeatedly.
• Miscoding
A couple of examples: timed codes that don’t hold up to the requirements, or one-on-one attendance codes when there was only one doctor present with five patients. Does anybody actually think this is going to get any easier with ICD-10?
• Missing information
This could by anything from the date of service to the doctor’s signature. Yes, you’re busy, but don’t put yourself at risk by rushing through documentation. It’s the only way to be paid for what you do without putting your practice at risk.
• Documentation that doesn’t support medical necessity
The rules on medically necessary care are simple and clear. There must be an episode of care with a clear beginning (onset or presentation), middle (treatment), and end (discharge from active care). There must also be the presumption that the patient will functionally improve from your treatment. Anything else is maintenance, wellness, or chronic care, and it’s not covered. Period. Time to figure out a payment plan with the patient (and to bring out the ABN, if you’re dealing with Medicare).
Documentation issues, paperwork piles, Medicare mies and regulations, and proper coding are all integral to running a safe and successful practice. It’s long past time for doctors
^Clearly, chiropractors need and deserve subject-matter experts, too. J Ï
and their teams to realize that educating the practice in how to improve documentation and compliance is almost, if not equally, as important as that degree they received in the first place.
Reach out to your own “board of directors” who can keep track of all of these issues so you don’t have to do so. Bringing your practice up to speed not only offers you peace of mind, but it’s the best way we know to increase revenue, decrease risk, and improve the bottom line.
Kathy Mills Chang is a certified medical compliance sPecia^lsl (MCS-P) and certified chiropractic professional coder (CCPC). Since 1983, she ’s been providing chiropractors with reimbursement and compliance training, analysis, and tools to help practices increase revenue and decrease risk. Kathy leads a team of 14 at KMC University and is known as one of our profession ’s
foremost experts on Medicare. She or any of her team members can be reached at 855-832-6562, at http://kmcuniversity.com, or by emailing info afmcuniversity. com.
