CMS recently published an update regarding the time frame for responding to pre-payment review Additional Documentation Requests (ADRs). Effective April 1, 2015, when a provider receives a pre-payment review ADR from a Medicare Administrative Contractor (MAC) or Zone Program Integrity Contractor (ZPIC), the provider will now have 45 calendar days to respond and supply the requested documentation. If the provider does not respond by day 46 the associated claims will be denied. This is a positive change to the response time frame – The current regulations (Section 3.2.3.2 (A) of the Medicare Program Integrity Manual), which will remain in effect until March 31, 2015, require providers to respond within 30 calendar days.
The new 2015 Medicare Fee Schedule has been posted to the carrier’s websites. In many regions, you will find a small bump in the reimbursement for 98940, 98941 and 98942. While other insurance plans are decreasing our reimbursement, Medicare continues to raise its fee schedule. Did you ever think Medicare would start to look attractive? Take this opportunity to also compare your prices to the Medicare Fee Schedule for other services.
The Office of Inspector General (OIG) has announced that they are currently conducting audits of chiropractic records. They will choose a date and you must send in all notes for the patient on the date requested, any supporting documentation, such as initial reports and re-evaluations, and notes pertaining to the patient six months prior to the selected date and three months after that date.
Keep in mind that a compliance plan in place as recommended by the OIG will act as a mitigating factor against possible fines and/or jail time as a result of these audits. This is NOT the typical Medicare audit by the contractors. This is from the OIG which is charged to maintain program integrity for all federally funded programs.
It is recommended that you have a compliance plan in place and upon a request for records, you respond in a timely manner. If you are selected for an audit, you should contact the ACA.