• McCoy M

• Costs and Cost Analysis
• Medicare
• Medicare / legislation and jurisprudence
• United States. Dept. of Health and Human Services
• Vertebral Subluxation Complex

Background: The Office of the Inspector General of the Department of Health and Human Services released a report dated May 2009 entitled: Inappropriate Medicare Payments for Chiropractic Services. According to the OIG report, Medicare inappropriately paid $178 million for chiropractic claims in 2006. This was out of $466 million in total claims paid. According to the medical claims reviewers hired by the OIG to conduct this investigation, the bulk of the inappropriate payments were for maintenance therapy which amounted to $157 million. Miscoded and undocumented claims accounted for the rest.

Discussion: This is not the first time the OIG has asserted that there were “significant vulnerabilities” related to Medicare payments for chiropractic care. Reports in 1986, 1998 and 1999 also alleged problems related to payment for maintenance therapy. According to this OIG report the previous studies recommended frequency edits or caps on the number of chiropractic claims allowed. In 2005 the OIG stated that 40 percent of allowed chiropractic claims were for maintenance therapy and they asserted that any visits over 12 in a year were likely to be for maintenance care. As a result, the OIG recommended that carriers conduct routine reviews of chiropractic services, implement frequency-based controls, target high-volume services for review and educate chiropractors on Medicare documentation requirements. This is what led to the massive effort in the profession to hold continuing education programs on Medicare and the PART system.

Conclusion: There are several concerns with this report from the OIG that include methodology, bias, and most distressing – perhaps a complete lack of understanding regarding the nature of the management of vertebral subluxation. The bold assumption is made by the drafters of this OIG report that fault lay at the feet of chiropractors however, the alternate suggestion is that perhaps the policies and procedures of the OIG, HHS, carrier staff and medical reviewers are ineffective, obtuse, contradictory and not based on sound science. The profession should call for an evaluation of the effectiveness of this program and its staff that takes into consideration this alternate view.

Author keywords: Medicare, chiropractic, vertebral subluxation

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