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Preparing for an Audit - The Time Is Now

Wednesday, March 29, 2017   (0 Comments)
Posted by: Dr. Ray Foxworth
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Preparing for an Audit - The Time Is Now


Chiropractors across the country have been opening up their mailboxes to find audit letters from Medicare. Although consultants have preached an increase in audits within the profession for years, many chiropractors were shocked to be the recipient of such a letter. You may be wondering why so many are being audited and what to do if you receive an audit letter at your office.


The audit is in response to the Comprehensive Error Rate Testing (CERT) program’s reviews of claims for chiropractic services. These reviews have consistently yielded a high number of improper payment rates. Because of these studies, CMS conducted a special study of claims for chiropractic services. The result of the CMS study showed “lack of documentation” as the most common reason for claim errors. In fact, the 2015 OIG report stated that $76 million in claims for chiropractic services was “questionable,” and an additional $21 million was “improperly paid.”


Some of the most commonly noted errors reported from CERT reviews include:


     Illegible/Missing signatures,

     Reproduced signatures (i.e., using a stamp instead of physically signing the document),

     Illegible documentation,

     Treatment suggestive of maintenance therapy, and

     Potentially upcoded claims.


If you receive one of these letters, the first and most important step you should take is to submit the requested information. Failure to submit the information will result in a 100% error rate by CMS, and they will begin to initiate an overpayment recoupment for these undocumented services. This will likely lead to further investigation. We recommend conducting a self-audit of the requested dates of service to determine if possible errors were made. If you discover errors, it would be wise to contact a certified coding expert or healthcare attorney for advice. Regardless of errors found during the self-audit, you should submit all records for the dates of service on the claim. Once a review of your notes is complete, you will receive a “letter of determination.” The results will notify you if any underpayments or overpayments were identified. You may be subject to repayments based on extrapolation if it is determined that overpayments were made. 


If you haven’t received an audit letter, take the time to complete a self-audit and begin taking steps to correct any deficiencies in your practice. Many consultants offer services to perform an audit on your practice. They can provide a report of their findings and give you the steps to correct any problems. Taking the initiative to complete an internal audit, documenting your findings, and then taking the corrective measures to prevent future errors shows auditors that you take compliance seriously.


To stay on top of compliance in your practice, sign up for our FREE weekly webinar series at





CMS Quarterly Compliance Newsletter, Guidance to Billing errors – Volume 3, Issue 3, April 2013


DHS OIG Report: CMS Should Use Targeted Tactics to Curb Questionable and Inappropriate Payments for Chiropractic Services -


Dr. Ray Foxworth is a certified Medical Compliance Spe­cialist and President of ChiroHealthUSA. A practicing Chiropractor, he remains “in the trenches” facing challenges with billing, coding, documentation and compliance. He has served as president of the Mis­sissippi Chiropractic Association, former Staff Chiro­practor at the G.V. Sonny Montgomery VA Medical Center and is a Fellow of the International College of Chiropractic. You can contact Dr. Foxworth at 1-888-719-9990, or visit the ChiroHealthUSA website at Join us for a free webinar that will give you all the details about how a DMPO can help you practice with more peace of mind. Go to to register today.


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