Chiropractic OIG Audit Recommendations - Lessons Learned

September 28th, 2018 - Wyn Staheli, Director of Research
Categories:   Audits/Auditing   Chiropractic   Office of Inspector General (OIG)   Medicare   Documentation Guidelines  
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The OIG recently concluded an audit on a chiropractic office located in Florida and had some significant findings. They recommended the following:

  1. Refund to the Federal Government the portion of the estimated $169,737 overpayment for claims for chiropractic services that did not comply with Medicare requirements and are within the 4-year claims reopening period
  2. Exercise reasonable diligence to identify and return the overpayments in accordance with the 60-day rule, for the remaining portion of the estimated $169,737 overpayment for claims that are outside of the reopening period, and identify any returned overpayments as having been made in accordance with this recommendation;
  3. Exercise reasonable diligence to identify and return any additional similar overpayments outside of our audit period, in accordance with the 60-day rule, and identify any returned overpayments as having been made in accordance with this recommendation; and
  4. Establish adequate policies and procedures to ensure that chiropractic services billed to Medicare are medically necessary and adequately documented

These OIG audit recommendations do not necessarily mean that this is the final determination and Medicare will follow all their recommendations. The MAC will likely be the one making the final determination as to whether a potential overpayment exists and they will also be the one to recoup any overpayments.

Even though the chiropractic office disagreed with the OIG’s findings on 31 of the 33 disputed claims and plans to appeal, there are some important things that every office can glean from their misfortune:

Now is a good time to take stock of your policies and procedures and ensure staff compliance. Conduct your own internal audit to review your medical record documentation and billing practices to be proactive in your approach to compliance.

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