CERT review addresses improper payments for chiropractic services

Findings from a Comprehensive Error Rate Testing (CERT) study show that insufficient documentation caused most improper payments for chiropractic services billed to Medicare in 2018, according to the July 2019 Medicare Quarterly Compliance Newsletter.

CMS limits coverage of chiropractic services to treatment by means of manual manipulation of the spine to correct subluxation. Chiropractic manipulative treatment (CMT) uses controlled, sudden force and twisting of the spine and extraspinal regions to relieve pressure, reduce inflammation, and improve nerve function.

Providers billing under Medicare may report three CPT codes for chiropractic services:

• 98940, CMT; spinal, one to two regions
• 98941, …; three to four regions
• 98942, …; five regions

The CERT review found a 41% improper payment rate on these claims in 2018, and of these errors, 88.3% were due to insufficient documentation. That improper payment rate places chiropractic services in CMS’ top 20 service types with the highest improper payment rates.

While the newsletter doesn’t provide further detail on the types of documentation errors made, it suggests that providers keep the following practices in mind to prevent future documentation errors:

• Documenting procedures: CMS encourages providers to document procedures as soon as possible after performing them.
• Medical necessity: Documentation should paint a clear picture of the patient’s baseline condition, treatments provided, and a treatment timeline.
• Self-audits: Providers should self-audit claims against records to help minimize errors that occur when preparing and submitting claims.
• Signature requirements: Providers should refer to the national provider signature requirements published in the Medicare Program Integrity Manual, Chapter 3, Section 3.3.2.4.

In addition, the agency encourages providers to review documentation requirements for initial and subsequent chiropractic patient visits. The Medicare Benefit Policy Manual, Chapter 15, Section 240, describes medical record documentation requirements of chiropractic services.