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Quick Intro
Report Summary: Claims
Resources (Education & References)
The Task Force (ACC, FCLB, COCSA, and ACA) & The Plan

In June 2005, the Department of Health and Human Services' (HHS) Office of the Inspector General (OIG) released a report titled "Chiropractic Services in the Medicare Program: Payment Vulnerability Analysis." Coming less than one year after ACA's successful battle to halt the implementation of frequency limits on chiropractic care, the report went through chiropractic claims and evaluated their documentation, eventually recommending that Centers for Medicare & Medicaid Services (CMS) start "a national frequency edit to target high-volume services--which are especially likely to be medically unnecessary--for medical review."

This report is a significant issue for the chiropractic profession. While some of its findings and recommendations can be argued with, ultimately, the documentation errors relayed in this report are generally consistent with what Comprehensive Error Rate Testing (CERT) Reviews have uncovered in the past few years about chiropractic documentation. In short, DCs simply must fix their documentation problem.

Sen. Charles Grassley (R-Iowa) made an appearance via video at the ACA's National Chiropratic Legislative Conference to talk about ACA's Medicare demonstration project and the implications of the OIG report. Grassley urged doctors of chiropractic to improve their documentation skills to prevent Congress from imposing frequency limits on chiropractic care in an effort to control costs. To view the video, click here.

• 94% missing required elements
• 67% medically unnecessary/miscoded
  • 40% maintenance
  • 14% not medically necessary (other)
  • 16% miscoded level 
  • 5% miscoded
• 6% missing documentation 

• Teleseminars

• Medicare Documentation Page
• -AT Modifier & Active v. Maintenance Care 
• Medicare Page
• JACA Article on Documentation 
• ACA Chiropractic Coding Solutions Manual
• ACA Clinical Documentation Manual (available at a reduced rate of $39 as a result of the Task Force response to the OIG report)
• The Actual Report from June 2005 - Chiropractic Services in the Medicare Program: Payment Vulnerability Analysis

• Coding Error and Other Documentation Clarifications by CMS
• Enhanced Regulatory Involvement
• Development of Chiropractic College Curriculum on Documentation
• Development of Continuing Education Program
• Distribution of Clinical Documentation Manual
• Formation of Formal Task Force
• Interim Emergency Workshops on CMS Documentation Compliance
• Profession-wide Outreach Campaign

The Task Force is due to issue a report to CMS, OIG, the U.S. Congress, and the chiropractic profession regarding this process no later than September 30, 2006.