Resource Centers:(News, information, and tools to support your practice)
July 2010
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Straight shootin’
How to determine whether you need a compliance consultant or not, and what to look for if you do
By Ted A. Arkfeld, DC, MS, CICE, CPC
Many types of consultants are available to the chiropractic profession — practice management, financial, and compliance consultants to name just a few.
But how can you determine whether or not you need to hire a consultant, or a compliance consultant, specifically?
To begin, honestly answer the following questions:
1. Does your office currently have a compliance officer who is constantly keeping abreast of the changing rules and regulations of healthcare? Does your compliance officer periodically hold training sessions for you and the staff?
2. Does your office have a certified coder in your insurance department?
3. Does your office run between 98 percent to 100 percent error free in insurance claims submissions? In other words, minimal, if no, claims rejections or denials for reimbursements from insurance companies?
4. Does your office fully understand the requirements of each evaluation and management code for new and established patient visits?
5. Does your office know the difference between a new and established patient?
6. Does your office have a complete understanding of what a five-level chiropractic manipulation treatment really entails (98942 CMT)?
7. Does your office understand what constitutes downcoding and upcoding, and how it can create a negative profile and loss of revenue?
8. Does your office prescribe massage therapy and active rehabilitation? Does your office understand what a timed-based code actually means?
9. Does your office understand the difference between maintenance and active care?
10. Does your office know that offering free exams or enticements to attract new patients is abusive and can lead to large fines?
11. Does your office know what profiling is and how it can work for or against you?
12. Does your office know how to work within the medical necessity definitions of Medicare and other third-party payers and still keep your chiropractic philosophy?
13. Would your case files and documentation validate your prescribed treatment for patients?
14. Does your office understand what a care plan really is and how it is a requirement for Medicare and all other third-party payers?
15. Are you, as a doctor of chiropractic, fully cognizant of your coding and billing submitted to Medicare and other third-party payers?
Your answers?
Is your head spinning? If you answered yes to all of the questions, you do not need a compliance consultant; however, if you answered no to any one of these questions, you do.
It can be overwhelming, and for 95 percent of chiropractic offices nationwide the above questions cannot be answered with a yes.
An instructor at Northwestern College of Chiropractic (NWCC) once stated, “If you don’t look for it, you will never find it.” Many doctors are not taught billing and coding to any great degree in chiropractic college; however, because your name is on the CMS claim form in box 32, you have a duty to ensure all coding and billing are accurate to Medicare and all other third-party payers.
“How can they expect me to do all of this?”
A doctor at a seminar on compliance a few months ago made this statement. He became very upset and voiced his displeasure and frustration on how he was supposed to treat patients, run a small business, and keep current on all compliance related matters.
The simple reply, “Hire a compliance consultant.”
Many of you may be thinking you can’t afford one because you are already struggling to meet the overhead in this down economy and here you are reading you must hire a compliance consultant. Some of you may even be thinking, “What is this thing called compliance?” or “I already have a HIPAA manual in my office,
Compliance means doing it right
Dr. Bryant Goldmon, who is a compliance consultant, eloquently states, “Compliance is doing the right thing every time.”
What does doing the right thing every time equate for your office?
One of the main benefits is increased revenues. Retaining a compliance consultant will allow you and your staff to be educated in the rules of insurance reimbursement. This provides you the knowledge of how to correctly code and bill for the services performed, which really means you get paid for the work you do.
So now that this “compliance stuff” is starting to look better and better, you are probably now wondering, “Where do I sign up?” Not so fast, as with any consultant, experience and credentials are a must.
Incorrect information being taught
Over the past three years, compliance consulting has grown due to the ever-rising number of post-payment audits sweeping across the country. New consultants are popping up everywhere, but buyers beware.
Some of these consultants are the same doctors who have been through audits, had to pay money back, and now feel they know everything regarding Medicare and post-payment audits.
Going through an audit is an educational experience, but it does not necessarily equate into genuine proficiency in compliance. Unless the consultant has the following credentials or work experience, the information they are teaching is questionable.
This may sound somewhat harsh, but incorrect coding and billing advice being taught can be even harsher.
Credentials, credentials, credentials
The consultant must have credentials that demonstrate he or she is serious about compliance. A compliance consultant should have at least one of the following certifications:
•CPC — Certified Professional Coder
•CPMA — Certified Professional Medical Auditor
•CICE — Certified Independent Chiropractic Examiner
In the absence of the above credentials, the consultant should have work experience in the area of compliance.
•Worked on a state or national level lecturing and consulting on compliance.
•Wrote compliance programs for chiropractic colleges and or insurance companies.
•Authored publications or books on coding, billing, and documentation.
Anything less than the above recommended credentials will have your practice playing Russian roulette with Medicare and other third-party payers due to questionable advice from an uncredentialed consultant.
Check out the potential consultant’s educational background and the source(s) of information being taught. If they are not citing the Medicare Manual for Chiropractic or the 2010 ChiroCode Deskbook, run away as fast as you can.
Time is of the essence
The time has come for all chiropractic offices to adopt a compliance program in order to ensure correct coding, billing, and documentation policies. This process begins with retaining the services of a well-educated and credentialed compliance consultant.
Outside the investment in your chiropractic education, this will be the wisest decision and will provide an excellent return on monies spent. Stop stressing out about new patients or patient visits and start getting paid for the work you perform. Hire a compliance consultant today.
Ted A. Arkfeld, DC, MS, CICE, CPC, is the president of Advanced Compliance Technologies PLLC, a consulting firm specializing in compliance programs, billing and coding, and proper documentation. He is also a Certified Professional Coder (CPC) through the American Academy of Professional Coders. He can reached at tarkfeld@arkfeldcompliance.com or through www.arkfeldcompliance.com.
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