RE: Medicare/OIG report

[Guest guest]

, and OR DCs,

This is old news and ACA and others have developed responses. But the

Office of the Inspector General report in June '05 is described as an

analysis of chiropractic Medicare claims conducted as follows:

" We contracted with practicing chiropractors who reviewed each service

according to a standard protocol, which was based on Medicare coverage

guidelines and requirements. The review instrument solicited information

about the beneficiary's chiropractic treatment as a whole and about the

individual sampled service in particular. This enabled the reviewers to

determine if the services billed to Medicare were covered, coded

correctly, and properly documented. In particular, it enabled the

reviewers to determine the extent to which payments were made for

maintenance services, which are not covered under Medicare. "

I am very curious to know if " the review instrument " is publicly

available, whether it has been validated and if, in fact it has been

shown to be able " to determine if the services billed to Medicare were

covered, coded correctly, and properly documented. " as the OIG contends?

On the other hand, it is possible that an improperly constructed

" instrument " or biased reviewers could significantly skew the results of

the study.

This sort of health services research is important in my view, but

highly politically charged. It should be open to objective scrutiny and

validation by replication, no?

A. Simpson, DC

Vice President, Medical Director

Complementary Healthcare Plans

6600 SW 105th Avenue, Suite 115

Beaverton, OR 97008

503-619-2041

csimpson@...

Re: Medicare on (long post)

Howdy ,

The OIG's report on chiropractic and Medicare has been a " hot issue "

with

much discussion on the Medicare chiropractic carrier advisory committee

of late. The committee is chaired by Ritch , DC, chairman of the

Medicare Advisory Committee for the ACA and consists of one or more

representatives from each of the 50 states, myself being the rep from

Oregon. This OIG report is very serious business and as you stated in

your post poses a serious threat to chiropractic participation in

Medicare. But please take note this situation is not being ignored.

Representatives of the chiropractic profession are proceeding full-bore

on state and national levels, including contacts with our legislative

reps, to address and correct this problem. I have pasted the press

release from the ACA and its action plan concerning this issue for your

review. I also encourage you to review the ACA website for more

information. The crux of the OIG report was concern over substandard

DOCUMENTATION. I emphasize that so each will understand how this

problem

can be resolved. So yes, we can expect Medicare to review our files,

past and present, in an effort to determine medical necessity (i.e. CERT

reviews). In fact, Medicare can now request patient records not just

for

the date in question but previous for many months. So we must be

extremely vigilant about how we DOCUMENT medical necessity. See the

following.

J. Holzapfel, D.C.

Albany, OR.

kjholzdc@...

FOR IMMEDIATE RELEASE

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Chiropractic Organizations Join Forces to Implement Comprehensive

Response to Inspector General Report

Detailed Action Plan Unveiled to Counter Documentation Errors

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(Arlington, Va. - Dec. 26, 2005) In response to a June 2005 report

issued by the Department of Health and Human Services (HHS) Office of

the Inspector General (OIG), which was highly critical of the

chiropractic profession's participation in the Medicare program, a

coalition of four chiropractic organizations today released a jointly

developed " Action Plan " intended to remedy the problems identified by

the HHS OIG.

The four organizations included in the task force are: the Association

of Chiropractic Colleges (ACC), the American Chiropractic Association

(ACA), the Congress of Chiropractic State Associations (COCSA), and the

Federation of Chiropractic Licensing Boards (FCLB).

The OIG Report, based on a random sampling of claims data from 2001,

concluded that 67 percent of the claims examined as part of the study

contained documentation errors or omissions that led to what the OIG

considered to be inappropriate reimbursement under Medicare. The report

also extrapolated that U.S. taxpayers could save more than $280 million

per year if improperly documented claims filed by chiropractors were not

paid by Medicare.

While documentation errors relating to Medicare claims are common to all

provider types, as a class, doctors of chiropractic have the highest

error rate in comparison to other provider groups.

Longstanding chiropractic supporters on Capitol Hill also took notice of

the OIG Report, and expressed concerns about Medicare documentation and

claims. Key staffers warned that legislative and policy corrections

could be externally imposed if the chiropractic profession did not

promptly undertake effective measures to significantly reduce the error

rates associated with chiropractic Medicare claims.

Recognizing the threat posed to the profession, and the harmful effects

on patients if access to chiropractic care were further limited in the

Medicare program, the four chiropractic organizations named above

quickly combined ideas and resources to prepare a comprehensive plan

that has the potential to improve the overall climate for federal

chiropractic claims.

The proposed Action Plan relies heavily on the cooperation of state

licensing authorities to develop mandatory continuing education courses

specific to the issue of documentation and that are targeted at Medicare

compliance. " We need to do more, and we all need to be part of the

solution. The licensing boards need to take a closer look at the

continuing education and ethical issues involved in solving this

problem, " said FCLB President Ed Weathersby, DC.

The plan also calls on chiropractic colleges to review their curricula

to ensure that chiropractic students receive comprehensive training on

proper documentation for " medical necessity. " " This appears to be an

education and training issue, " said ACC President Zolli, DC.

In addition, the plan relies on the cooperation of COCSA-member state

associations to work closely with the ACC, ACA and state licensing

boards to offer a number of quality continuing education opportunities

that are uniform in content. The four groups comprising the Task Force

will work together to develop " model " content for these training

programs, with a core program unveiled by May 2006.

COCSA President Steve Simonetti, DC, promised strong support by state

associations. " State associations will lead the effort by informing

doctors of chiropractic about the problem, and then by providing

opportunities for DCs and their staff to receive proper training to

eradicate these filing errors. " As a result of the Action Plan, every

licensed DC should have multiple opportunities to access Medicare

documentation training in the next 12 months.

To sustain the continuing education component of the Action Plan, the

ACA has agreed to make copies of its recently published Clinical

Documentation Manual available at cost to the entire profession. " The

first step has been taken with development of the Clinical Documentation

Manual. Now we must turn every practitioner's attention to the details

involved with filing claims properly, " said ACA President G.

Brassard, DC.

In early 2006, the Task Force will also widely circulate an " Open

Letter " to the chiropractic profession reiterating how important it is

for DCs to properly document Medicare claims.

While the burden of implementing the Task Force Action Plan falls almost

entirely on the chiropractic profession, the four organizations fully

recognize that there are outstanding issues related to carrier

administration of the Medicare program that must be addressed.

Therefore, the joint Task Force also plans to work directly with

Medicare's designated carriers to identify ways in which they can

standardize and improve the processing of chiropractic Medicare claims.

A target date to meet with carrier representatives is Jan. 31, 2006.

To read the Task Force's Action Plan, visit the ACA Web Site at:

http://www.a catoday.com/government/medicare/docs/OIG_TaskFor

ce_ActionPlan.pdf

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today.com%2Fgovernment%2Fmedicare%2Fdocs%2FOIG_TaskForce_ActionPlan.pdf>

..

For more information:

Kargus

Communications & Public Relations Manager

akargus@...

Phone: (703) 218-0240

For more information:

Felicity Feather Clancy

Vice President, Communications

ffeather@...

Phone: (703) 218-0241

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