Posted by Dr. Don Cross on December 18, 2015
We ain’t all bad apples…
Love my grammar? This was the first thing that crossed my mind when I saw Dr. Ron Short’s article in Dynamic Chiropractic a couple of weeks ago. If you didn’t catch the article, please read it. It’s worth your time. Here’s the link http://www.dynamicchiropractic.com/mpacms/dc/article.php?id=57547.
The article’s title is “Targeting the Bad Apples in the Bunch,” and he’s addressing the OIG’s latest report on chiropractic billing errors. When I was attending the last Summit meeting, we were given a report on the OIG’s report then which was in agreement with what Dr. Short expressed. Both agreed with me, we ain’t all bad apples.
In fact most of us are doing an adequate job with the limited resources we have, and the OIG’s report shows that. I’m confident that we are doing a good job of following the guidelines in my office and so are the people using the systems in the ObamaCare Compliance Manuals.
Do we occasionally make chiropractic compliance mistakes? Of course, but we have methods to catch those mistakes before they become problems requiring CMS and their team of auditors to step in and solve them for us. That’s what doing your due diligence is all about. Not waiting till someone else finds a problem, but looking for and correcting our mistakes ourselves, which is the core of being in compliance today. That is not how “the Bad Apples” are operating, and as the OIG’s report indicates, those are the offices that need to be focused on by the auditors.
With the New Year comes a few actions that you should be following up on in your office. Of course the most time consuming and strenuous are our self-audits. The annual risk assessment is the most critical and unfortunately one of the most forgotten.
Pull out last year’s and review it before you start. (If you don't have a chiropractic compliance program in place, I urge you to get started immediately.) Did you follow up and complete the corrective actions? Are they documented? If not, don’t forget them this time.
As an aside, don’t ever discard your old risk assessments. I just had a Meaningful Use audit for the first reporting period in 2011. Yes, five years ago! Of course one of the required pieces of documentation was my risk assessment for that period. I still had it, it wasn’t as pretty as my current one, but it still had what they were looking for in my audit! Always remember, your documentation is your biggest asset and your best defense.
Join me in a few weeks as I give a free chiropractic compliance webinar on being prepared for the New Year. I will go through a checklist of things that you and your staff should be addressing as we start 2016.
Happy New Year,
Don M. Cross, DC, CPCO