Resource Centers:(News, information, and tools to support your practice)
March 2010
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Are you winging it?
The multidisciplinary practice
By Mark Sanna, DC, ACRB Level II, FICC
A troubling trend has happened as multidisciplinary practices have increased in popularity over the last few years.
More and more chiropractors are undertaking the conversion of their chiropractic practice into a multidisciplinary practice without the legal and managerial assistance of professionals experienced in this highly regulated area.
In a Chiropractic Economics survey, 28.7 percent of chiropractors responded they currently practice in a multidisciplinary setting, but only 24.7 percent of those who practice in a multidisciplinary setting responded they work with a practice-management/consulting group. If this is you, you are winging it.
In a traditional chiropractic practice, the necessity of keeping up with ever-evolving rules and regulations is more important than ever. A multidisciplinary practice brings its own unique, and at times complex, set of rules and regulations, and failure to comply can bring unforgiving penalties.
For the unwary practitioner, the result of winging it can be disastrous from both a financial and legal perspective. The lack of proper guidance often results in improper corporate structure, unmet professional staffing requirements, and scrambled accounting and billing practices. Noncompliant documentation of the services rendered places licensed and unlicensed staff members (including CAs and associate DCs) at jeopardy for post-payment audits by third-party payors and compliance audits by the Office of the Inspector General and other federal and state regulatory agencies.
Chiropractors had five common responses when asked what multidisciplinary practice concerns they had. A review of these responses should provide you with insight into some of the reasons why winging it is not an option.
• I don’t know the legal requirements. Multidisciplinary practice brings federal and state-specific legal requirements. In some states, a multidisciplinary practice requires a complex corporate structure composed of three to four unique corporate entities, while other states permit a single corporate entity that varies only slightly from that of a solo chiropractic practice. For this reason, it is essential to work with a healthcare attorney well versed in the legal requirements for multidisciplinary practice in your state.
• I don’t know the staffing requirements. The professionals most frequently associated with chiropractors in a multidisciplinary setting are massage therapists (21.3 percent), MDs (12.3 percent), physical therapists (PT) (11.2 percent), and acupuncturists (9.0 percent).
The Chiropractic, Medical, and Physical Therapy Practices Acts are state-specific and regulate the scope of practice of each of their respective professions. In addition, the Stark Laws mandate federal staffing and referral requirements.
In some states it is actually illegal for a chiropractor to employ an MD or PT. In others, you can hire professional staff with the same ease as lay staff members. An experienced consultant should be able to clarify the specific staffing requirements for your state.
• I don’t know the coding rules. The Center for Medicare and Medicaid Services (CMS) regulates the coding rules for both chiropractic and multidisciplinary practices, and therefore leave no room for creativity or practice-specific interpretation.
CMS oversight provides the benefit of being able to view these regulations in black and white, with no shades of gray. While CPT coding is an ever-changing process, it is completely clear in the Official ACA Policy Statement on Multidisciplinary Practice that only those services provided by a chiropractor may be billed under the provider number of a chiropractor.
Likewise, those services provided by other
• I don’t know the costs. Without proper management, the increased overhead associated with additional professional staff members can become a drain on your bottom line and tax your ability to produce a return on your investment.
In the area of financial management, it is essential to seek professional advice. Before considering a multidisciplinary practice, a consultant should help you perform a careful analysis of your patient flow and demographics, the healthcare needs of your community, and the availability of professional staff for hiring — all in the context of your current financial circumstances.
You should not undertake a multidisciplinary practice without sufficient capital to see your practice through startup and into the growth and development phase.
• I don’t know the marketing. Approximately 10 percent of the general public seeks chiropractic care, and that statistic has remained unchanged for decades. The fear factor associated with a chiropractic visit by many nonpatients virtually evaporates when an MD or PT joins your staff.
The number of individuals willing to consider chiropractic, or refer a friend or family member to you as an alternative to traditional medical care, increases many fold. In addition, it is common practice for MDs to refer patients to other healthcare professionals; unfortunately, chiropractors are typically not in that circle of referrals.
The conditions that respond best to chiropractic care are those same conditions that most frustrate traditional MDs. In the absence of an acute healthcare crisis, many MDs are at a loss as to how to care for conditions that have been proven, through documented research, to respond excellently to chiropractic care.
Conversion to a multidisciplinary structure places your practice in the center of the circle of referrals from the medical community. The right consultant should help you maximize the unique marketing opportunities of your multidisciplinary practice.
The benefits to patients of providing care in a well thought out, correctly structured, multidisciplinary setting are many. The efficiencies of providing multiple healthcare services in one location result in an improved coordination of professional communication, higher-quality care at a lower cost, and greater convenience to your patients.
Investing in the best legal and consulting advice is like buying an insurance policy for the success of your practice. Don’t wing it.
Mark Sanna, DC, ACRB Level II, FICC, is the CEO of Breakthrough Coaching. He can be reached at 800-723-8423, by e-mail at info@mybreakthrough.com, or through www.mybreakthrough.com.
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The official word
In 2005, the ACA Fraud Sub-Committee, under the Insurance and Managed Care Committee, developed an Official ACA Policy Statement on Multidisciplinary Practice. The committee included doctors in private practice from across the country, chiropractic leadership, insurance industry representatives, and legal counsel.
The result was a document that, for the first time, provided a clear-cut blueprint for what is and isn’t acceptable in a multidisciplinary setting. This document should be part of the Compliance Manual of every multidisciplinary practice.
**See a copy of the Official ACA Policy Statement on Multidisciplinary Practice at www.ChiroEco.com/MDPpolicy.
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