Certified CA training is changing the face of reimbursement while strengthening and protecting practices.
By Laurie Mueller, DC
In May 2013, the Federation of Chiropractic Licensing Boards (FCLB) announced their new Certified Chiropractic Clinical Assistant (CCCA) guidelines, establishing an application process and a national examination that extends standards of chiropractic excellence to CAs.
Because other professions have long- standing training credentials for medical assistants, physical therapy assistants, dental assistants, and so on, this step was crucial for chiropractic’s credibility. It also aims to reduce patient risk and vicarious liability in chiropractic offices.
Several states have had formal regulations in place for years: Oregon, Florida, and Tennessee to name three. However, with a national program now up and running, the profession may encounter regulatory changes in many more states, and third-party payers may also look to require CA training if any billable modalities involve the CA working with a patient. This could certainly affect future reimbursement.
NCMIC has reported that about 5 percent of claims stem from burns to the patient. This is likely the result of modality use — and most probably the result of untrained staff. Such cases would fall under the vicarious liability category for offices.
According to the ACA website, “‘Incident to’ is a phrase that describes the delivery of certain services through an individual other than the actual healthcare practitioner, e.g., electrical stimulation performed by a chiropractic assistant ‘incident to’ a doctor of chiropractic. As of July 25, 2005, for therapy to be reimbursed in Medicare, the therapy must be delivered by either a physician or someone that qualifies as a ‘therapist.’”
Can FCLB’s national program fit the bill for such Medicare regulations? The answer is yet to be seen, but it certainly creates more credibility for the chiropractic profession and offers a route to prove competency. Meanwhile, other third-party payers who are being billed for services performed by office employees who don’t have documented training could start requiring CA training for reimbursement, citing the national certification as a standard. Many are already following suit with Medicare.
The FCLB quoted UnitedHealthCare as saying “services rendered by non-licensed individuals are not eligible for reimbursement.” BlueCross/BlueShield of Kansas City similarly stated: “Supervised treatment in the absence of skilled intervention is not billable time.” If services are not provided by individuals with documented training, insurance companies retain the right to reverse payments — including the electronic recovery of funds.
The FCLB solution to this ongoing issue was to create standardized training guidelines and testing for a formal national certification for chiropractic clinical assistants.
The FCLB proposes the following core curriculum components:
Foundational knowledge: The successful CA should have general entry-level knowledge necessary for working in a practice. Examples of areas requiring basic knowledge include
Patient safety and procedures: The successful CA should have at least an entry-level ability to complete tasks related to patient treatment, and recognize and appropriately respond to situations that may compromise patient safety. Examples of such items include
Documentation: The successful CA will have at least an entry-level ability to complete tasks related to the creation, handling, and storage of patient data, including the billing of patient services. These tasks may include
Ethics and boundaries: The successful CA will exhibit ethical decision-making ability and recognize appropriate interpersonal boundaries. This section of the test contains basic scenarios pertaining to the following
The current guidelines and exam are heavily weighted toward passive-care modalities, and do not currently include active care (exercise); however that may change in coming years.
Whether mandated or not, in light of patient protection, safety, and office liability, CA training can increase the competency of CAs, increase patient confidence and safety, and decrease office risk and liability.
It can take months or years for an untrained CA to learn everything on the job. With guidelines and programs in place, doctors can now train current and new CAs and ensure minimum competency for their offices, and likely help satisfy the new insurance mandates.
Laurie Mueller, DC, was the post-graduate director for Palmer Colleges from 2000 to 2010. She served as the Acc post graduate subcommittee chair for six years, peer reviewed for the Research Agenda Conference, and wrote the role determination study that aided in the development of the FCLB’s guidelines for CAs. She currently works as a private eLearning consultant with a focus on healthcare topics. She can be contacted through CCCAonline.com.