"The issue is real and it must be addressed head-on," stated American Chiropractic Association (ACA) President Anthony Hamm, DC. "Proper documentation is integral to our work moving forward to further integrate the essential services provided by chiropractic physicians in Medicare. Poor documentation is not only a black eye on the profession; more importantly, it reflects poorly on the deliverance of quality-driven care for our patients."
Of particular concern to ACA are those DCs who exhibit documentation patterns that are incongruous with the majority of DCs whose claims are submitted appropriately. As the OIG report found, "Just two percent of chiropractors were responsible for half of the questionable payments" and were located in high-fraud areas.
The most recent report fails to cite work ACA has been conducting for the last two years regarding Medicare documentation education and training. Since 2013, ACA representatives have traveled around the country to work with Medicare Administrative Contractors (MACs) specifically on the subject of improving and harmonizing documentation. At the 2015 National Chiropractic Leadership Conference (NCLC) in February, ACA invited contractor medical directors from all MACs to attend a round table discussion on Medicare documentation, and that meeting has spawned a significant uptick in ACA/MAC relations and ideas on how to reduce the error rates.
"Earlier this year, for the first time, we were able to come together with all the MACs, roll up our sleeves and get to work on solving the ever-present documentation conundrum," Dr. Hamm said. "I'm confident that all DCs will heed the call to focus on clearing our profession of this scornful stigma."
In addition to the MACs, ACA is working with HHS to implement provisions called for under the Protecting the Integrity of Medicare Act (PIMA), passed as part of Medicare reimbursement reform earlier this year. Under PIMA, HHS is charged to collaborate with ACA and the MACs to develop and implement an education program dedicated to chiropractic documentation in Medicare. That education program, by statute, is to become available early next year.
"ACA continues to work for a solution with all stakeholders to ensure that proper Medicare documentation to support active care for Medicare beneficiaries is employed," said Dr. Hamm.
For more information on Medicare issues, please visit www.acatoday.org/medicare