The rewards are great, but chiropractors must adapt to new policies and procedures with a multidisciplinary medical practice
Emerging in the contemporary practice environment is the increased collaboration between health care professionals. MDs, PTs and DCs are converging for the purpose of delivering comprehensive services to patients whose conditions warrant a joint approach to care via a multidisciplinary medical practice.
Multidisciplinary practices (MDPs) offer patients a broader scope of coordinated services than those available in either a medical, physical therapy or chiropractic practice alone. They can also deliver these services in a more efficient and cost-effective manner. These are the steps to take (and those to avoid) that will help provide effective care in an efficient way in an MDP.
Multidisciplinary medical practice legal compliance
The decision to establish a MDP can be beneficial to chiropractors who have achieved a measure of success and are interested in taking their practice to the next level.
The creation of a MDP requires several preliminary steps starting with the recruiting of medical personnel, as well as the creation of the proper corporate structure. State corporate laws and scope of practice regulations control how multidisciplinary practices must be formed and operated. These requirements vary dramatically from state to state.
When establishing your multidisciplinary medical practice, it is best to retain local legal counsel familiar with the group practice health care laws and regulations of the state in which the practice will be established. Beware of “ghost” or “on-paper-only” physician ownership. In states that require an MD to own all or part of the stock in the MDP, the owning physician must have a documented and ongoing role in the practice. In addition, all stockholders of the MDP should make a financial contribution to that corporation as well as performing all other steps of corporate compliance.
While successfully operating a MDP can be rewarding, those rewards can quickly disappear should the chiropractor and other professionals involved not adhere to the most stringent policies and procedures. A MDP is not a method to change a chiropractic practice into a medical practice with a few legal sleights of hand. It is not a method of increasing reimbursement revenues by misrepresenting chiropractic services as medical, nor is it a method of fraudulently obtaining insurance coverage for chiropractic treatment that would otherwise not be covered. A MDP should be created for the benefit of its patients.
MDP billing procedures
In all practices, including MDPs, the provider that performs the service must be identified on the insurance claim form. Chiropractic services, those services and procedures performed by a DC, are never to be billed under an MD’s provider number. All chiropractic services are billed under the DC’s provider number. Chiropractic services are never billed incidentally to a medical license. MD and PT services are similarly identified.
A multidisciplinary medical practice is a group practice working under one tax ID number, and identifies services performed by the individual practice members by provider number. No duplication of services should occur by the various professional providers. For example, Manual Therapy (97140) should not be billed under a chiropractor’s provider number and, during the same encounter, under a physical therapist’s provider number.
Patients with Medicare or any other Federal Health Insurance Program should not be seen as MDP patients unless the physician-level staff meets the 75% Rule federal staffing requirement and are present in the facility at the time the services are rendered. If the 75% Rule staffing requirement is not met, patients of the practice may receive chiropractic care, performed by the chiropractor, based upon their consent and medical necessity.
A MDP should have an effective compliance program in place. This includes the designation of a compliance officer or committee, a baseline compliance audit and annual compliance audits. The fee schedule of the MDP should be reasonable and customary for the region in which the practice is located.
MDP service offerings
Expanding the services provided in your MDP can generate additional sources of new patients and diversify your revenue stream. Chiropractors without a medical provider on staff are required to refer these services to medical colleagues outside of their practice. In MDPs, many of the procedures can be performed by your medical team members with some additional education and training required.
- Trigger point and facet joint injections may be an option in treating pain for some patients. When chiropractic, physical therapy, anti-inflammatory medications, and muscle relaxants have not provided the relief of pain, injection of the painful trigger points or facet joints with a local anesthetic and steroid medication may provide lasting relief.
- The field of regenerative medicine includes emerging therapies that have the potential to heal damaged and painful tissues in ways that were unheard of just a few years ago. These therapies have the potential to fully heal injuries and damaged tissues that might otherwise be beyond repair. Regenerative medicine provides patients with options that allow them to improve their function and quality of life and decrease their possibility of becoming dependent on harmful medications.
- Bioidentical hormones are an exact molecule-for-molecule match to the hormones that the body naturally produces. Bioidentical Hormone Replacement Therapy (BHRT) is a powerful solution to restore peak performance and reduce the aging process. Customized programs are individualized to specific goals — every patient is given a specific formula.
- Intravenous Nutrition Therapy (IVNT) is a safe and effective method of delivering vitamins, minerals and amino acids directly into the bloodstream. IVNT overcomes nutritional deficiencies by introducing them directly into the body, bypassing many of the obstacles within the digestive system that might prevent absorption. The 30-45-minute sessions enhance energy, improve mood, and help prevent future health conditions caused by stress, malnutrition and dehydration.
A multidisciplinary approach
Your multidisciplinary medical practice professional support team should also take a multidisciplinary approach, with non-lawyer professionals working in conjunction with lawyers. When lawyers and other professionals from various disciplines such as accountants and management consultants work together, the results are superior.
Take this approach and you can help ensure the long-term legality and profitability of your practice.
MARK SANNA, DC, ACRB LEVEL II, FICC, is a member of the Chiropractic Summit and a board member of the Foundation for Chiropractic Progress. He is the CEO of Breakthrough Coaching and can be reached at mybreakthrough.com or 800-723-8423.