Medicare Update: Comprehensive Error Rate Testing Chiropractic Services
The CERT program’s review of claims for chiropractic services has consistently yielded high improper payment rates. The majority of chiropractic services claims were the result of insufficient documentation, such as:
- Documentation submitted did not adequately describe the service defined by the billed procedure code or modifier
- Treatment plan was not submitted
- Signature on notes was illegible
Documentation Requirements
For the initial chiropractic visit, the documentation must include the following information:
- Patient history
- Description of present illness and evaluation of musculoskeletal/nervous system through physical exam
- Diagnosis (primary diagnosis must be subluxation)
- Treatment plan
- Date of initial treatment
The physical examination must demonstrate at least two of the four following criteria:
- Pain/tenderness
- Asymmetry/misalignment
- Abnormal range of motion
- Tissue/tone changes
One of these criteria must be either asymmetry/misalignment or abnormal range of motion.
For each subsequent visit, the documentation requirements include:
- Patient history (lists such items as changes since last service)
- Physical examination
- Documentation of treatment provided at each visit
- Progress or lack thereof, related to treatment goals and plan of care
Documentation of the initial evaluation/periodic re-evaluations at reasonable intervals is essential.
Initial Evaluation
- Patient’s presenting condition (symptoms, physical signs, and function) must be described in objective, measurable terms along with pertinent subjective information
- Must provide a clear description of the mechanism of injury and how it negatively impacts baseline function
- Clear plan of treatment that includes:
- Recommended level of care (duration and frequency of visits)
- Specific treatment goals
- Clinical milestones to be used as measures of progress
Re-evaluations
- Demonstrate the patients’ progress in objective, rather than conclusory terms
- The evaluation elements, noted in the initial evaluation need not be documented at each treatment; however, they must be present often enough to show measurable progress, or failure to progress
Updated treatment plan must:
- Document modifications when needed because of failure to satisfactorily progress in the clinically reasonable and predicted timeframe
- Demonstrate that the treatments provide more than merely short term symptom control without any associated longer term functional
View the podcast: Improving the Documentation of Chiropractic Services
Related Content
- CMS IOM Publication 100-02, Medicare Benefit Policy Manual, Chapter 15, Sections 30.5 and 240
- CMS IOM Publication 100-04, Medicare Claims Processing Manual, Chapter 12, Section 220
- Local Coverage Determination (L33613) Chiropractic Services