Jurisdiction K Part B Prepayment Audit Results for CPT Code 98941

Background


A service-specific prepayment audit was conducted by the National Government Services Medical Review Department for Jurisdiction K (JK) Part B claims in Connecticut and New York. The audit focused on claims billed with CPT code 98941, (chiropractic manipulative treatment [CMT], spinal, 3-4 regions) for the following states/locations:
  • Connecticut (implemented in January 2012),
  • Downstate region of New York (implemented in April 2012),
  • NY Queens County (implemented in August 2011), and
  • Upstate region of New York (implemented in December 2011).
Medical records will be requested to verify medical necessity of the services provided, and that services were billed according to Medicare Program guidelines. If the submitted documentation does not support CPT 98941, the services will either be correctly coded to an appropriate/lower level (98940) or denied for reasons listed below.

Findings

During this audit, documentation was reviewed to adjudicate claims for payment based on the LCD and Medicare coverage guidelines. The following results are based upon the completion of the review for JK Part B.

State/Location...................May 2013.....June 201......July 2013.....Total
Connecticut.........................93.8%.........94.2%.........98.2%..........95.4%
New York Downstate.............92.8%.........88.2%.........89.5%..........90.2%
New York Queens County......97.4%.........96.4%.........100%...........97.9%
New York Upstate.................93.3%.........79.7%.........78.4%..........83.8%

High error rates resulted from claim denials related to documentation not supporting medical necessity requirements of the LCD for Chiropractic Services (L27350). Key issues identified are:
  • Lack of patient’s specific subjective complaint – A relevant medical history in a patient’s record must indicate a beneficiary subjective complaint(s) and the area(s) of complaint(s) should correlate to the area(s) of subluxation(s) cited and/or treated.
  • Lack of functional status- Documentation does not describe a patient’s current level of functioning and activities of daily living, nor treatment goals related to functional levels.
  • Lack of objective documentation of specific level(s) of subluxation in the exam – The precise level(s) of subluxation must be specified by the chiropractor to substantiate a claim for manipulation of the spine. The level(s) of spinal subluxation must bear a direct causal relationship to the patient's symptom(s), and the symptom(s) must be directly related to the level(s) of the subluxation that has been diagnosed. Documentation needs to be clearly legible without the use of abbreviations, checks or circles that provide minimal and unclear information. If using P.A.R.T (P=pain, A=asymmetry, R=range of motion, T=temp, tone, tonicity) exam, the documentation requirement must be fully met per policy. Policy requires documentation of two of the our criteria, one of which must be asymmetry/misalignment or range of motion abnormality.
  • Lack of area(s) of CMT that corresponds to subjective complaint(s) – The specific spinal area(s) that was treated on the day of the visit must be clearly documented and the area(s) treated must correspond to patient’s subjective compliant(s). Documentation needs to be clearly legible without the use of abbreviations, checks or circles that provide minimal and unclear information.
  • Treatment plan and goals not documented/not addressed – Documentation of a treatment plan must include the recommended level of care (duration and frequency of visits); specific treatment goals and objective measures to evaluate the treatment effectiveness. The patient’s progress or lack thereof related to the established treatment plan and goals should be addressed on subsequent visits. If treatment continues on without evidence of improvement or the clinical status has remained stable for a given condition, further manipulative treatment is considered maintenance therapy and is a non-covered benefit.
  • Documentation supporting maintenance – Maintenance therapy is a noncovered benefit. Examples of maintenance therapy would include long-term treatment per history without the documentation supporting exacerbation, subjective complaint of “minimal pain” on multiple visits without showing improvements or no positive response – documentation remains the same or template for multiple visits. Also, documentation of “chronic” condition with no documentation to support an exacerbation and/or improvement.
Other issues that resulted in claim denials include:
  • Nonresponse to development letters – When an ADR letter is received, submitting information and appropriate documentation suggested in the ADR letter is required to consider payment of the claim in question. If the requested medical record is not submitted in a timely manner, the services will be systematically denied.
  • Illegible Documentation – Medical record must be legible. If the reviewer cannot decipher the documentation, it may result in the denial of a claim.
  • Missing or illegible provider signature – Documentation must be legible and include a provider’s signature. The method used can either be electronic or handwritten, stamp signatures are not acceptable. A signature key or signature log can be included with the documentation to identify the author associated to the illegible signature.
  • Incomplete or missing beneficiary information – A patient’s medical record must include a legible beneficiary name for identification. Also, the medical record should be clearly dated and correspond to the date of service billed. If this information is missing or incomplete, it may result in denial of a claim.

We recommend that you perform random sample claim audits within your practice to ensure that these errors do not exist. You may also use the errors identified in the prepay audit as a checklist before submitting future claims. Please also take time to review the LCD and SIA for Chiropractic Services (L27350). The LCD and SIA can be accessed from the Medical Policy Center on the National Government Services Web site. Enter L27350 in the CMS Identifier Number search field and select Go to initiate an LCD search in the CMS Medicare Coverage Database.

References

Posted 09/13/2013
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Source: www.ngsmedicare.com

 

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