CMS, Comparative Billing Report (CBR)
Please share this info with other D.C.'s

Updated: October 28, 2010
Dear Doctors and Staff,
A random faxed Comparative Billing Report (CBR) was, and is still, being faxed to only Chiropractors.  This report issued by Safeguard Services(a CMS contractor) is a specific comparative report for individual Chiropractors versus your Chiropractic peers.
This report is only designed to be beneficial as an educational tool which may assist you in identifying opportunities for improvement.  It is my understanding from the Safeguard Services, that information on you and the results of your comparative billing is kept in house and not forwarded to your carriers.
The reason for this report on Chiropractic services is from the 2009 Office of Inspector General's report published regarding Chiropractic claims billed with the "AT" modifier, that exceeded 12 treatments per beneficiary.  Based on a random sample of these claims, the study revealed 47% were paid inappropriately.  This represented $178 million in inappropriate payments for maintenance therapy.  Maintenance therapy is not covered by Medicare.
In another OIG study, it was determined that as Chiropractic services extend beyond 12 treatments a year it is more likely that the services are medically unnecessary.  The chances of a service being medically unnecessary increases even more significantly after 24 treatments.
This author believes the OIG reports to be flawed reports.  The OIG assumes that if the Chiropractor can not document the Chiropractic necessity of care, then the care must have been maintenance care.
The problem is not that the Chiropractic care was maintenance, (the Chiropractor did correct a subluxation which is the covered service in Medicare), but the problem is that most Chiropractors "believe" S.O.A.P. notes are documentation and do not produce "documentation" by federal standards to make a payable claim payable.
Until Chiropractors learn the correct way to "document" in Medicare, the OIG will continue taking away our privileges as Medicare providers, and also take away from the consumer (our patients) their freedom of health care choices under Medicare. 
BOTTOM LINE: If you wish to learn how to do Chiropractic Medicare correctly, including "documenting" by federal standards, please consider ordering our Chiropractic Medicare DVD and booklet. It explains piece by piece every important step in doing and billing Chiropractic Medicare so there are no limits for the chiropractic adjustment. If you are audited you will have done Medicare correctly and win your audit. You and your staff will be very happy you have this important and mandatory information. I promise it will make a difference in your understanding of Medicare and how you bill Medicare.
Seminar Schedule
Keep in mind, Medicare is the only insurance type program that if done incorrectly is fraud, a felony, a fine and/or jail.

I promise you will be more than satisfied that you made the right decision to purchase this information or attend our presentation. Please give me a call if you have questions. 1-618-395-3162

Best regards,
Dr. Gary R. Street

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