There has been a lot of talk and a lot of panic surrounding the ideas of “compliant” billing, coding or documentation in the chiropractic practice.
Most of you who have read my blog or attended my seminars are well aware of our poor performance as a profession in this arena and the backlash that has ensued in terms of post payment audits, claim denials or payment delays.
Following a recent column of mine in Dynamic Chiropractic (Insider Secrets About Postpayment or Recovery Audits), I received a wave of requests for templates that create “bullet proof” documentation every time. Similarly, I get more questions than I can physically answer from random chiropractors wanting to know if certain procedures they utilize fit the definition of a specific CPT code. Finally, either before (or in some cases, after) an audit, many DC’s (and even professional billers) have emailed me asking if a certain methods of billing are legit.
Most of these questions come from hard working, well meaning and nice chiropractors who are probably a lot like you in the most basic sense. Some are from worried DC’s who are on the verge of audits. Many are from individuals irritated or angry with the system that we play within which changes rules and requirements arbitrarily and seemingly without much notice.
In a number of different ways, all of these questions revolve around the same issue: how can I create a “defensible” system for what I do on a daily basis?
While this is an excellent question, there is no simple answer. First, let me dispel a few myths, then allow me to explain my lack of cookie cutter response.
Audits Don’t Presume Guilt Nor Innocence
Let’s be clear on one thing: Just because someone requests your notes does not automatically mean you have done something wrong. It may be a sign of some questionable practices on your part, or it may just be your random luck of the draw. Don’t take it personally, unless there is a pattern that emerges that you need to fix.
Even if a payer suggests that your practice patterns are outside industry norms, regional averages or plan parameters, it STILL does not mean you are a bad egg. However, it generally will mean that you have to justify why you act, look or treat differently than others.
Finally, while the above scenarios are certainly true, do not for one moment believe that you operate “above the law.” Statistically speaking, as a chiropractor, you create a mess that stinks just like many of our colleagues. And if third party payers persistently or frequently request your notes, delay your billings or force you to argue over the care you rendered, there is a good chance your mess needs some cleaning up before the stink sabotages your clinic or before you no longer have a business that you refer to as your practice. License plate manufacturing does not look good on a chiropractor’s resume.
Why Some DC’s SHOULD Be Scared
While this may sound like unnecessary scare tactics to some of you, let me remind you that I have seen enough chiropractic documentation to know that there is a significant portion of you who SHOULD be very scared! Here’s why:
1) There are few of you who have taken adequate steps to protect yourselves from audits. I have met no chiropractic equivalents of the above bicycle owner, who is obviously well-protected, if a bit paranoid.
2) If you repeatedly asked me to give you $50,000 per year and I was generous (or dumb enough) to give it to you with hardly any questions as to what, where, or why you needed the money…how long do you think this scenario would go on before I started asking some questions about the perennial need for this funding?
While this may sound like a strange question, how is it much different than many insurance scenarios?
Sure we provide a service to our patients. But if we don’t adequately communicate what we did in that service to deserve payment (via our billing, coding or documentation) why would or should the insurance company keep paying us?
Furthermore, why wouldn’t the insurance company want to take some of that money back if we didn’t provide them with an adequate “receipt” (again, in the form of our billing, coding and documentation) for our services?
When you put things in this perspective, it is not too surprising that third party payers are auditing doctors of all types. Sure they already are making tons of money and probably don’t need the extra dough they are squeezing out of the hard working docs but…they can, so they will.
Creating a Defensible Plan
Our job, then, is to reduce the impact of insurance profiteering on our practices. We do this by adhering to proper standards of billing, coding or documentation. By creating a record of what we did and why we did it. And by learning and staying up-to-date with the rules so that we can keep our noses clean.
This is how you create defensible documentation, coding or billing. Those interested in learning, I look forward to bringing you more of this information via my blog, webinars and seminars in 2010. Those who are well aware that they need this information customized to their specific practice needs and requirements , you would do well to have me take a look “under the hood of your practice.” The first step is to complete a FREE, no obligation FREE Practice Analysis.
Best wishes for a successful 2010!
Tom
