Commit to airtight documentation or risk the future of your practice.
In the Chinese Zodiac, 2015 is the Year of the Sheep. In the world as defined by the venerable New York Times, 2015 is the Year of the Condo. But in chiropractic, 2015 is most definitely the Year of Documentation. And if you don’t have systems in place to “build” bulletproof documentation, it could also be your Year of the Audit.
Is this news? Haven’t you been hearing about increased scrutiny from the Office of Inspector General (OIG), soaring records requests, and zealous HIPAA-compliance watchdogs for a while now? Yes, you have. And yes, this is still news. Because as widespread as OIG and third-party payer scrutiny has been, it promises, from the OIG’s own lips, to get even more intense.
And, just to make things extra interesting, you’ve got an added complication in October, when healthcare providers across the country will be required to convert to ICD-10 coding. How will your documentation look then?
Consider some of the following takeaways, from the OIG’s recently published Work Plan:1
Seventy-six percent of OIG’s funding is for overseeing Medicare and Medicaid.
A dry statistic? Think bigger. DCs can’t opt out of Medicare. So all that well-funded scrutiny includes looking at you. It’s critical that you know just what they want to see in your documentation—how would it pass muster if put under the Medicare and OIG microscope?
As Medicare goes, so go most third-party payers.
Some DCs believe that because they don’t treat many Medicare patients, they don’t have to pay attention. Not so. If you bill any other carrier, the OIG’s word is essentially the letter of the law. Those insurers will be equally inspecting your documentation.
This is big money: The OIG estimates its 2014 recoveries from audits and investigations at $4.9 billion.
If you had this kind of potential revenue stream, would you take your foot off the gas, or would you put pedal to the metal and make the most of it? Yes, the OIG thinks so, too. Ensuring that your documentation is impeccable means that money won’t be coming out of your pocket.
The potential consequences of an audit aren’t just financial.
During 2014, the OIG excluded 4,017 “individuals and entities” from participating in federal health insurance programs, and brought 971 criminal actions and 533 civil actions against suspected offenders. For those who think getting kicked out of Medicare would be a relief, consider that if you get booted from Medicare participation, most other carriers will drop you like a hot potato. At the extreme end of potential consequences, there’s possible jail time and loss of your license.
DCs are tarnished by the same brush used on fraudulent practitioners.
In other words, the OIG is going into 2015 with the presumption that it will find the same kind of inappropriate payments for medically unnecessary treatment rendered by chiropractors that it found last year. It believes it has identified patterns of abuse, noncompliance, and fraud, and will be looking at you and your colleagues with the intention of finding those same patterns.
There’s a lot more information in the 90-page Work Plan, but the key takeaway for chiropractors can be boiled down to this: With ICD-10 in the mix this year, your risk of making unintentional documentation errors increases exponentially. And you know that the OIG and its third-party carrier followers are out there, actively looking to make money off your mistakes.
Many doctors don’t know what they don’t know. This year, more than ever, it’s essential that you find out. Because with auditors on the hunt, what you don’t know can cost you your practice.
Kathy Mills Chang, MCS-P, has been providing chiropractors with reimbursement and compliance training, advice, and tools to improve the financial performance of their practices. She leads a team of 14 at KMC University and is an expert on Medicare and documentation. She can be reached at 855-832-6562 or firstname.lastname@example.org.
1 U.S. Department of Health and Human Services, Office of Inspector General. “Work Plan Fiscal Year 2015.” http://oig.hhs.gov/reports-and-publications/archives/workplan/2015/FY15-Work-Plan.pdf. Released October 31, 2014. Accessed February 2015.