The new federal health care law, the Patient Protection and Affordable Care Act as amended by the Reconciliation Act (PPACA), REQUIRES chiropractors to adopt a compliance program as a condition of participation under Medicare.

A compliance program should, at a minimum, incorporate HHS Office of Inspector General’s recommendations for compliance. This includes a comprehensive establishment of OIG elements, a breakdown of all guidelines for coding and documentation, and an analysis of fraud and abuse laws as they relate to chiropractors. A compliance program, to be effective, should include all of these laws and guidelines.

The Martin Law Firm, an experienced health law firm with a focus on chiropractors, has developed a compliance program based on federal law and OIG recommendations. Specifically, the health care compliance program for chiropractors, as created by the Martin Law Firm includes, but is not limited to the following topics:

  • Standards for compliance
  • Guidelines for billing and reimbursement
  • Documentation requirements for Treatment Plans and SOAP Notes for accurate reporting of medically necessary services
  • CMT documentation standards
  • Billing for Evaluation and Management services
  • Therapies and modalities
  • Time based codes and how to document the services
  • Use of modifiers
  • Fraud and abuse laws including Anti-Kickback, Stark, False Claims Act and civil monetary penalties
  • Education and training policies
  • Investigation and Corrective Action Plans
  • Legal business arrangements for chiropractors who want to hire massage therapists, physical therapists and other providers
  • Legally discounting care with prompt pay or time of service discounts

A comprehensive compliance program will save the chiropractor money by reducing risk, avoiding the flags that trigger post payment reviews, protecting reimbursement and profits and helping to resolve payment disputes with Medicare and other insurance payers.

Federal law mandates that all chiropractors adopt an effective compliance program. Private insurance payers expect that all chiropractors implement one. All chiropractors who want to ensure compliance should contact the Martin Law Firm today.