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| ProviderLAW Advisory | |||||
Have You Recently Received a Request for Records From Medicare? If So, You Should Read This Advisory. Specifically, Medicare is Requesting to See Copies of Treatment Plans. What Are the Required Fields in a Medicare Treatment Plan? | |||||
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A copy of this advisory |
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| Drafted by: ProviderLAW | |||||
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As many of you are aware, last week ProviderLAW released its study on recoupment. While the study focuses initially on Medicare law, and on the major limitations against Medicare carriers performing recoupment, we urge all practices to closely examine the study irrespective of the degree to which they treat Medicare patients. A copy of this study can currently be accessed through our public directory. In the near future, we will be addressing more specifically the issue of recoupment by ERISA health benefit plans. The purpose of today's advisory is to focus on a few key points made in the recoupment study. For reasons that will become more clear as this advisory progresses, we believe that these points apply to all specialties that provide extended care, such as chiropractic, physical therapy, and rehabilitation. If you have recently received a request from a Medicare carrier requesting records, the following excerpt from our study may be of interest to you. |
...[I]n June of 2005, the Department of Health and Human Services, Office of Inspector General (OIG) issued a report entitled, "Chiropractic Services in the Medicare Program: Payment Vulnerability Analysis." In this report, the OIG claimed that approximately 67% of chiropractic claims in 2001 were paid in error resulting in $285 million in improper payments. Subsequently, the OIG recommended that carriers should begin to "obtain and review the records of [chiropractors] ... in order to identify and collect overpayments" (p. 16, emphasis added).... |
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Subsequent to the OIG report, a group of affiliated Medicare carriers disseminated model letters for requesting records from chiropractors dating back six (6) months. You can view these letters at pages 8-11 of the CERT Newsletter, September 2005. Notably, Both the Newsletter and the Sample Letters Mention the Need for Providers to Supply Copies of a "Plan of Care," – I.e., a Treatment Plan. The Medicare Carriers Manual and Code of Federal Regulations specify the fields which your treatment plans must include when it comes to extended care situations, such as chiropractic, physical therapy, and rehabilitation. In conjunction with dK Coding and Compliance, Inc., ProviderLAW has recently developed a treatment plan template for extended care situations based on the Medicare Carriers Manual and Code of Federal Regulations. A copy of this treatment plan template is loaded in the practice forms section of our web site. Also, we have published an audit checklist for evaluating whether the treatment plan you are currently using – whether in hardcopy or in your documentation software – includes the fields required by the Medicare Carriers Manual or Code of Federal Regulations. This audit checklist is likewise published in the practice forms section. If you have questions regarding these resources, please do not hesitate to contact us. |
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Legal Notice (Rev. 05-01-07): This Legal Notice ("Agreement"), Located Online at http://www.providerlaw.com/legal_notice.php and Accessible Through Various Menu Options, Contains the Basic Terms Associated with All Resources Of, and Agreements With, ProviderLAW as Well as with Designated Resources of Ancillary Entities. You Are Responsible for Reading These Terms Carefully as a Condition of Using this Web Site, as Well as of Purchasing, Using, and Relying Upon, ProviderLAW Resources. The Terms Include Without Limit the Terms of Subscription, Business Associate Agreement (To the Extent Required by Hipaa), Licensure of Multimedia Products, Conference Participation, Web Site Use, and Privacy, as Well as General Terms Common to Agreements. The Resources of ProviderLAW and/or of Other Ancillary Entities Do Not Constitute Legal Advice, Cannot Be Relied upon as Legal Advice, and Do Not Establish a Client-attorney Relationship. Such Resources Are Provided for Educational, Awareness, and Discussion Purposes Only and as Such, Are Provided Strictly as Samples or Illustrations. While ProviderLAW and Other Ancillary Entities May Be Able to Assist You in Finding an Attorney, Unless Otherwise Stated, ProviderLAW and Other Ancillary Entities Are Not Law Firms and Do Not Offer Legal Representation to Any Third-party. If You Have Questions of a Legal Nature, You Should Contact an Attorney at Law. "ProviderLAW," "ProviderLAW Corporation," and "ProviderPRO.net" are fictitious names of the ProviderLAW Knowledgebase, Inc., a Pennsylvania corporation.... [ Click Here for Terms ] |
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