In the wake of insurance denials, some chiropractors pose an interesting question in their attempt to get paid for what they do. It is some variation of this:
“If I billed something incorrectly…or the insurance company denied a particular service…or procedure A was bundled with procedure B…can I change my records/billing/coding so I can get paid for this?”
Certainly, my loyal blog readers know that one of the two primary purposes of my writing this column is (1) to help you maximize reimbursements by getting you paid for ALL the work you do. But this purpose is also coupled with keeping you compliant in your billing, coding and documentation while attempting to achieve my other goal for you, which is (2) to minimize your audit risk.
In other words, I would love to see every chiropractor paid well for all of the work they do (not more than they deserve, but not less) and, of equal importance, possess the proper documentation necessary to KEEP the money they earned.
Answering the question(s) posed then is not a simple “yes” or “no” but an “it depends.” Let’s explore this a little further.
Amendment of Records Can Be a Good Thing
Amendment of a medical record can be a good thing. Reviewing your records to check for accuracy and completeness and taking the time to amend them is common and commendable. We all know that the daily duties and pace of practice often cause us to spend less time taking notes that we may want to or that good documentation may warrant. Therefore, a practice of reviewing notes before the day’s end, for example, can be a good way to catch any missed items needing documentation as well as prevent incorrectly billed or coded services.
Obviously, the best practice is to complete your records correctly the first time. But if you didn’t, you can make an addition or correction later. You must do so in a legitimate and above-board fashion—timely and not apparently an “alteration.” Different payers may have varying definitions of what constitutes “timely” documentation, but most appear to indicate that the note should be completed during the actual encounter of shortly thereafter. Most payer descriptions I have seen of this seem to indicate “shortly thereafter” means within 24hours after treatment.
Avoid Alteration of Records
Let’s differentiate between the terms: “Amendment” or “Alteration.” For our discussion, Amendment refers to the process of reviewing and/or correcting mistakes within a short period of time (as above) for the purposes of correction. Alteration, on the other hand, does not quite convey the same corrective intent.
For example, if you alter your records once a lawsuit has been filed or an attorney has requested your records, it’s too late and this would not be considered a legitimate “correction” or amendment of the patient’s file.
Unfortunately, this is a common scenario: you receive a request for records, review your documentation, and see that some fact is omitted or some entry is inaccurate. You quite innocently think that you can “improve” the record.
Let me stop you there. Don’t do it.
Every state chiropractic board in the country has heard numerous cases of records alteration and, I am sure, cringes every time they have to review one.
In reality, the insurance company, plaintiff’s attorney, claim review company and who knows who else has likely already obtained a copy of your records in their original form. As the jury is shown both the original record and your “revised” record, you will see your credibility disappear before their eyes – even if the alteration of the record was innocent, helpful or minor.
At the least, any alterations you make in the records significantly after the treatment date can be viewed as self-serving. Taken to the extremes, it can also be regarded as a cover-up or potential fraud. (See picture at start of blog for what technology can do to squash your attempts to alter records anyway!)
Adding To or Correcting Records
What should you do if you discover an omission? Suppose you review your earlier progress note and discover that you forgot to state that you made an appointment for a patient x-ray? Or what if you reviewed the x-rays and in the process of documenting your findings, inadvertently left a key finding out of your report?
Sometimes, omissions may not have clinical relevance but are needed for accuracy. For example what do you do when you discover that a simple typing error has made your 26 year old patient 62 years old?
In cases like these, adding a note can illustrate the fact that you are a conscientious chiropractor by demonstrating that you are careful enough to review your notes and concerned enough to add the missing information.
To properly amend records, you need to:
- Put a notation in the margin next to the original entry: “see my note below.”
- Enter another note at the time you discover the error. Write in the added information. Initial and date it.
- Draw a single line through the incorrect entry. Make sure that the original entry is still legible.
- Explain the correction. If possible, explain why the earlier note was incorrect, the reason for the error, and the reason the error was noticed.
On the other hand, erasing, using correction tape or fluid, or obliterating any documentation in the record is unacceptable and would be a big no-no that can land your tail in hot water.
Many chiropractors contact me – after the fact – about their claim denials, payment disputes or billing problems which may have occurred as a result of errors or ignorance. Some of these problems are correctable.
If you legitimately performed a procedure, documented it correctly and simply forgot to bill for the procedure alongside the other services that were rendered during that visit, you may wish to submit a corrected claim and get reimbursed for this. Provided you do this in a timely manner, the insurance should reprocess the claim and pay for your for the service.
Similarly, if an insurance company has denied your service based on a claim submitted with the wrong code on it (due to a human error, mistake, number dyslexia, etc), re-submit your claim for payment consideration. In these instances, I find a short letter submitted with the corrected claim to be helpful. (i.e. Dear Sirs, I inadvertently billed for 58940 instead of a 98940. There was no Oopherectomy performed, in part or total, during the course of the patient’s chiropractic visit nor was it my intention to attempt to get paid for one. The service performed was…)
Some billing problems, however, should not be corrected.
For example, adjusting 3-4 areas of the spine (98941) and performing manual therapy (97140) in one of those same areas won’t fly with payers and will result in a denial. If you have billed this out and find a rejection letter staring you in the face, you should not downcode your service to a 98940, re-bill it and hope to be paid for your “corrected claim.”
Presuming you did adjust three or four areas in the first place, it would be fraudulent to downcode because you are essentially lying to get paid. Again, take your lumps and correct the issue.
Likewise, if you bill for a service only to find it denied, you should not re-submit the claim using a different code in an attempt to get paid. Look in any coding book, page 1 or thereabouts and you will see instructions that read something like “Select the name of the procedure of service that most accurately identifies the service performed.”
Spaghetti billing methods (throw it to the wall, see what gets paid/sticks) are not advisable, inefficient and potentially fraudulent.
Parting Words of Wisdom…From Bob
So what do you do if you have a billing problem that causes you to lose money, but which you cannot correct if you wish to keep your nose clean?
- Identify and research the issue so that you can understand the problem.
- Seek experienced help. Billing and coding errors rarely occur in isolation. Typically, I find multiple errors that are costing my clients thousands of dollars in unrealized income or potential losses.
- For future purposes, and on the lighter side, see Bob Newhart’s classic advice on the matter below. A little on the rough side, but technically accurate! J
To Your Success!
Tom Necela, DC, CPC, CPMA