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9/9/2019
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The Most Expensive Documentation
Mistakes Chiropractors Make
Presented by Evan M. Gwilliam, DC MBA BS
CPC CCPC QCC CPC-I MCS-P CPMA CMHP AAPC Fellow
Clinical Director
Dr. Evan Gwilliam
• Education• Bachelor’s of Science, Accounting - Brigham Young University
• Master’s of Business Administration - Broadview University
• Doctor of Chiropractic, Valedictorian - Palmer College of Chiropractic
• Certifications• Certified Professional Coder (CPC) - AAPC
• Certified Chiropractic Professional Coder (CCPC) - AAPC
• Qualified Chiropractic Coder (QCC) - ChiroCode
• Certified Professional Coder – Instructor (CPC-I) - AAPC
• Medical Compliance Specialist – Physician (MCS-P) - MCS
• Certified Professional Medical Auditor (CPMA) – AAPC, NAMAS
• Certified ICD-10 Trainer – AAPC
• Certified MIPS Healthcare Professional (CMHP)– 4Med
• AAPC Fellow 2
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Take Away
• Identify the top mistakes DCs make
o Fees schedules
oMedical necessity
oCloning
o Lousy diagnoses
o Lousy care plans
oGet a handle on SOAP and CMS requirements
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One Fee SchedulePolicy must be written and applied consistently
Once fees are set, they can only be discounted when there is:
• Financial hardship discount*
• Prompt pay / time of service (TOS) discount*
• A contractual obligation
• A special group rate*
*depends on state guidelines
Hardship1. Document carefully and place in patient chart
2. Obtain documented proof, if feasible, such as income tax return
3. Set a threshold based on a sliding scale that follows federal poverty guidelines and offer it to anyone who qualifies
4. Place a time limit on the waiver
5. Do not offer routinely
6. Make reasonable collection efforts first
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Hardship
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HRSA - Health Resources and Services Administration.
HRSA is the "primary Federal agency for improving access to health care services for people who are uninsured, isolated or medically vulnerable."
HRSA has developed a Hardship Application based on federal poverty guidelines
See ftp://ftp.hrsa.gov/nhsc/applications/sliding_fee.pdf
Poverty Guidelines -- http://aspe.hhs.gov/poverty/
Post a sign that says that no one who is unable to pay will be denied access to services.
Hardship
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Prompt Pay2008 OIG Advisory Opinion• Prompt pay is a discount that
o "is designed to reduce the Health System's accounts receivables and costs of debt collection, and to boost its cash flow."
o "bear[s] a reasonable relationship to the amount of collection costs that would be avoided."
o 5%-15% is reasonable
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Prompt Payo Also known as a Time of Service discount, can be
immediate or within a few days
o Not recommended by the ACA because of unique state/federal laws
o Be very cautious with pre-pay discounts. Set up an escrow account.
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Prompt Pay Discounts
Talk With Your Attorney
“Fr”
Services?
Not Advertised
In Writing &
Consistently Applied
ReasonableNot
Based on
Length of
Care
“Non-Covered
Services” Only?
Notify
Payer?
Discounts
1. May not advertise that payments from insurance will be accepted as payment in full
2. May not waive copays to induce patients to refer
3. May not fail to make a reasonable collection effort
4. Be careful not to create a “dual fee schedule”
5. Each state may have unique rules (military discount)12
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RVU based fee analysis
Contractual Obligations
Actual fees DMPO fees
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• 98940 $45
• 98941 $62
• 99202 $120
• 99203 $175
• 72100 $150
$28
$40
$72
$105
$95
1. Managed Care Organizations (MCO) such as Blue Cross
2. Discount Medical Plan Organizations (DMPO) such as ChiroHealthUSA
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Contractual Obligations
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A DMPO works just like an insurance plan, except the patients pay you directly
• Get credentialed – it costs you nothing
• Set your “network” fee schedule
• Post that you are a network provider
• Make sure to go with a licensed and bonded discount Medical Plan – e.g ChiroHealth USA
• Patient signs up with the plan for $49 per year
• They can now enjoy the “in-network” fee schedule
Documentation
• Outlines a clear course of care and the patient’s
response to treatment
• Provides clear evidence of continuity of care to
communicate with other providers
• Acts as a legal record of the care given
• Allows comparisons between differing patient
episodes as well as other patients with similar
conditions
• Supports the billing for services rendered
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Documentation
Is your documentation a weakness to be
exploited by those who do not want to pay?
Or, is it a shield that protects you from
liability and audits?
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Medical Necessity
“Services or items reasonable and necessary
for the diagnosis or treatment of illness or
injury, or to improve the functioning of a
malformed body member” -CMS
How can you prove medical necessity?
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Chain of Medical
Necessity
1. History of onset→
2. Patient complaint→
3. Exam findings→
4. Diagnosis→
5. Treatment plan→
6. Progress
Chain of Medical
Necessity
1. History of onset• Explain why the patient has a complaint
• Document mechanism of trauma for acute patients
• For chronic patients, try to establish why the patient
decided to come in today, rather than another time
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Chain of Medical
Necessity
2. Patient complaint→
3. Exam findings • Relate exam findings to complaint
• Functional loss should be documented in the
complaint (ADLs) and consistent with the exam
findings.
Chain of Medical
Necessity
4. Diagnosis• The diagnosis should provide a plausible explanation
for the symptoms.
• Clinical criteria from the history and exam should
match up with the diagnosis.
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Chain of Medical
Necessity
5. Treatment Plan• Should be appropriate for the diagnosis.
• Care given because of provider technique, philosophy,
or just routine is not medically necessary.
• Treatment should transition from passive to active.
• Avoid cookie cutter care. Plans should vary for
different ages and different diagnoses.
Chain of Medical
Necessity
6. Progress• Goals should be specific to each patient and
measurable
• Outcomes Assessment Tools are the best way to
quantify functional progress
• Goals must be evaluated and updated over timeSee chapter 4.5 of the DeskBook for more on goals
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Chain of Medical
Necessity
1. History of onset→
2. Patient complaint→
3. Exam findings→
4. Diagnosis→
5. Treatment plan→
6. Progress
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Chiropractic Services Targeted
• 2014 CERT Improper Payment Report
o 54.1% of chiropractic claims were paid improperly
• 92.2% of those improper payments were due to
insufficient documentation
Denials• Payers often believe that services rendered
were unnecessary because:
o There were too many visits
o There were unnecessary services at each visit
o Billing does not match documentation
• Good documentation can prove that:
o The visits were medically necessary
o The services were needed to help the patient get better
o The billing is an accurate reflection of the record
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Bad records can cause:• State board action
• Claim payment denial
• Administrative heartburn
• Miscommunication between payers and the doctors
Bad Records
A well organized chart• Intake forms
• Initial Evaluation
o Imaging reports
oDiagnoses
o Care plan
• Daily visits
o progress
• Re-evaluations/discharge
o progress
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1. Why did the patient begin care?
2. What did the provider find wrong?
3. What did he/she do about it?
4. How did care end?
Problem Oriented Medical Record
1. Complete problem list
2. Diagnoses for each problem
3. Treatment goals for each problem
4. Written treatment plan for each problem
5. SOAP notes for ongoing treatment of each problem
6. Date of resolution or referral for each problem
Problem Oriented Medical Record
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• One chart per patient, regardless of payer
• Name and DOB should be on each page
• Pages should be numbered and chronological
• Missed appointments, displeasure, and negative events should be recorded
• Correspondence with attorneys, insurance companies, and referrals should be recorded
• Handwritten records are not recommended
• Use standardized abbreviations
• Sign, legibly within 24 hours
Quality Patient Records
• Illegible records
• Missing dates
• Missing signature
• Missing informed consent
• Missing re-assessment
• Missing patient identifiers
• Missing metrics/objective
• Blanks used to indicate “WNL”
• Missing legend for abbreviations
• Missing care plan
• Cloned records
• Billing only 98940 or only 98941
• Using travel cards38
Common Errors
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Cloned Records
• Watch out for “text spinners” or “random text generators”
• Consider:oQuoting patient statements
o Patient age, severity of condition, complicating factors
o Specific goals that mention actual ROM or OATs score for that patient
oDiagnoses that are specific. (i.e. more than just pain and subluxation)
oHighlighting changes to help reviewers 40
Avoiding Clones
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Avoiding Clones
• Illegible records
• Missing dates
• Missing signature
• Missing informed consent
• Missing re-assessment
• Missing patient identifiers
• Missing metrics/objective
• Blanks used to indicate “WNL”
• Missing legend for abbreviations
• Missing care plan
• Cloned records
• Billing only 98940 or only 98941
• Using travel cards42
Common Errors
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Cloned records
• Watch out for “text spinners” or “random text generators”
• Consider:o Patient age
o Severity of condition
o Specific goals that mention actual ROM or OATs score for that patient
oDiagnoses that are specific. i.e. more than just pain and subluxation
oComplicating factors44
Avoiding Clones
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1. Demographics including:• The facility or location where the study was performed
• Name of patient and another identifier such as date of birth or record number (this is a HIPAA standard)
• Name or type of examination
• Date of the examination
• Inclusion of the following additional items is encouraged:
• Date of dictation
• Date and time of transcription
• Patient’s date of birth or age
• Patient’s gender
2. Relevant clinical information such as patient history or exam findings that elicited the need for the imaging
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Radiology Reports
3. Body of the report• Findings: use appropriate anatomic, pathologic, and radiologic terminology
• Potential limitations that may affect the quality of the films, such as patient habitus or expected artifacts
• Comparison studies and reports if available
4. Impression (conclusion or diagnosis)• A specific diagnosis should be given when possible
• A differential diagnosis should be rendered when appropriate
• Follow-up or additional diagnostic studies to clarify or confirm the impression should be suggested
when appropriate
• Any significant patient reaction should be reported
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Radiology Reports
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• Electronic signatures can beo Electronic image using a pen tablet
o Digitized and confirmed by valid software
• Unacceptable signatures include:o illegible signature or initials, not over
typed/printed name, not on letterhead, not accompanied by a signature log or attestation statement
o unsigned note with provider's printed name
o "signature on file"
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Signatures
Acceptable signatures include:
• legible first initial and last name
• illegible signature over typed or printed name, or with
clear letterhead
• illegible signature with a signature log or attestation
statement
• initials over a typed or printed name, or accompanied
by a log or attestation statement
• unsigned handwritten note where other entries on the
same page in the same handwriting are signed
Signatures
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Abbreviations
1. Nerve-related disorders (e.g. radiculopathy)
2. Acute injuries (e.g. sprains and strains)
3. Structural diagnoses (e.g. degenerative disc disease)
4. Functional diagnoses (e.g. difficulty with walking)
5. Symptoms (e.g. neck pain)
6. Comorbidities (e.g. diabetes)
7. External causes (e.g. place and activity)
Diagnosis Hierarchy
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ICD-10-CM Updates
2016 2017 2018
New codes 1,943 363 279
Revised codes 422 252 143
Deleted codes 302 142 51
Deleted Oct. 1, 2016: • M50.12 Cervical disc disorder with radiculopathy, mid-cervical
region
New Oct. 1, 2016:• M50.120 Mid-cervical disc disorder, unspecified
• M50.121 Cervical disc disorder at C4-C5 level with radiculopathy
• M50.122 Cervical disc disorder at C5-C6 level with radiculopathy
• M50.123 Cervical disc disorder at C6-C7 level with radiculopathy
ICD-10-CM Updates
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Deleted Oct. 1 2017:
• M48.06 Spinal stenosis, lumbar region
New Oct. 1, 2017:
• M48.061 Spinal stenosis, lumbar region without neurogenic claudication
• M48.062 Spinal stenosis, lumbar region with neurogenic claudication
ICD-10-CM Updates
As of October 1, 2018, there will be 71,932 active ICD-10 CM codes.
Deleted Oct. 1, 2018: • M79.1 — Myalgia
New Oct. 1, 2018:• M79.10 — Myalgia, unspecified site
• M79.11 — Myalgia of mastication muscle
• M79.12 — Myalgia of auxiliary muscles, head and neck
• M79.18 — Myalgia, other site
ICD-10-CM Updates
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MONEY
What are audits all about?
Who is selected for an audit?
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DC statistics to consider:
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37%
32%26%
99204 99205E/M usage
99201
99202
99203
4%
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61%
32%
7%
CMT Frequency
98941
98940
98942
DC statistics to consider:
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From the ChiroCode DeskBook
• Medicare requires providers to have a Care Plan
• Boards of Examiners require Care Plans
• Insurance Carriers require a Care Plan
• Today's patient’s demand them
• It shows you have gone through the decision making process – How can I get this patient better?
Why is a Care Plan Important?
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Compliant Care PlansTreatment Schedule
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Local Coverage Determination (LCD): Chiropractic Services (L33613), page 6National Government Services, Inc.
Care Plans: Medicare
Care Plans: BCBS
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• Why are you treating the patient?
• What are you going to do with the patient?
• How long and how often are you going to see the patient?
• What are you and the patient trying to accomplish?
• How do you know when you have accomplished the goals?
Care Plans: Dr. G
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• Diagnoses
• Complicating factors (if applicable)
• Stages of care (benchmarks)
o Procedure/service details
o Body area for that procedure/service
o Duration and frequency of each procedure/service
o Short term goals/rationale specific to that procedure/service
• Long term goals for the entire episode
• Prognosis71
Elements of a Care Plan
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• Tie the treatments to the diagnoses
• For example, the purpose of 97110 Therapeutic exercise is to develop/improve strength, endurance, range of motion, and/or flexibilityo Diagnoses like M54.2 cervicalgia may not support this service
o But diagnoses like M62.81 muscle weakness might
• 98943 Extraspinal manipulation should not be linked to spinal diagnoseso Such as M50.3- Other cervical disc degeneration
Procedures / Services
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• Set up a “trial” that is adaptable based on evaluations rather than a long term cook book plan for all patients. Move through stages as benchmarks.
• CMS recognizes that:o Acute treatment is shorter duration, higher frequency
o Chronic treatment is longer duration, but lower frequency
• The literature suggests that you use a combination of 1. clinical expertise
2. patient expectations
3. evidence-based guidelines
Duration and Frequency
Patient’s Values and Expectations Best Research
Evidence
Individual Clinical Expertise
Best Practices
‘Best’ Best Practices
BP
BP
BPBBP
BP
BBP
Also: customersconsumerspolicymakers
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Clinical Practice Guideline: Chiropractic Care for Low Back Pain
(J Manipulative Physiol Ther. 2016; 39, by Globe G,
Farabaugh RJ, Hawk C, Morris CE, Baker G, Whalen
WM, Walters S, Kaeser M, Dehen M, Augat T.)
Three places you can learn more:
• http://clinicalcompass.org/ccgpp/new-for-2016
• http://www.jmptonline.org/article/S0161-4754(15)00184-0/abstract
• ChiroCode DeskBook, chapter 4.4 Treatment Plans
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• Only address frequency and duration of visits
• Neglect goals entirely
• Include goals, but
o They are only subjective
o They do not address function
o They are not measurable
Weak Care Plans
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1. What is the activity (sleep, walk) the patient will be able to perform?
2. Under what conditions (how far or for how long) will they be able to do it?
3. How well will they be able to do it (without assistance, without increased pain)?
4. When will this be accomplished (2 weeks, 2 months)?
Keep them patient-centered!
Goals
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Short term goals restated:1. Reduce pain2. Increase pain-free ROM3. Restore normal vertebral segmental motion4. Increase ability to move affected area
Short term goals improved:1. Reduce VNRS from 8/10 to 5/10 within 2 weeks2. Increase pain-free ROM by 50% within 2 weeks3. If you restore normal vertebral segmental motion, you can’t
adjust anymore, right?4. Same as number 2?
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Two weeks later
Assessment should discuss progress towards goals • Were goals achieved?• If not, why?
• Patient went on vacation• Patient fell down the stairs
• How will the care plan change to adapt to goals that were not met?• Easier or harder exercises?• More or fewer visits? • Referral or new diagnostic test?
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Short term goals restated:1. Reduce pain by 10% 2. Increase strength (Is there documented loss of strength?)3. Increase endurance (How do you measure this?)4. Increase ability to move affected area (Measurable?)5. Increase ability to exert force to affected area
AND (these are better)
1. Get 5-6 hours of quality sleep (within what time frame?)2. Stand for more than 20 minutes (Is this from Oswestry?)3. Sit for more than 20 minutes pain free4. Walk for more than 1 block pain free5. Lift more than 20 pounds from off the floor
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OATs
OATs Inspired Goals
• Goals need to be measurable and specific
• Change ADL by this much by this date
“Improve NDI from 60% to 30% by re-evaluation scheduled for 6/1/18”
“Enable patient to lift heavy weights without pain by 5/1/2018.” - from NDI, section 3
“Improve ability to stand without pain from 30 minutes to one hour by 5/20/2018.” - from Oswestry, section 6
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OATs
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OATs
• 10% improvement = minimum detectable change• 30% improvement = meaningful change• 50% improvement = substantial change
• Consider re-administering questionnaire at a minimum of every 30 days and also at midpoint of initial trial of care (i.e. 2 weeks)
• Consider using overall OATs score as a long term goal and specific ADLs for shorter term.
• Overall OATs score may work best with major injuries because in chronic cases it may just go up and down.
Prognosis is used to forecast the probable result of treatment for a patient’s condition.
Short term – symptomatic
Long term – functional
1. Excellent
2. Good
3. Fair
4. Poor
5. Guarded
6. Unstable
Prognosis
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1. Excellent – full symptomatic and functional recovery expected within 2-4 weeks
2. Good - Symptomatic and functional recovery is expected in approximately 4- 8 weeks but the patient may experience intermittent mild pain and some restriction of motion
Prognosis
3. Fair - The patient can expect to have a reduction of their symptom although some persistent pain and stiffness from the injury is expected and may require ongoing rehabilitation.
4. Poor - The nature of the patient’s injury and preexisting conditions bring into doubt the likelihood of full recovery. It is expected that patient will continue to experience intermittent to occasional paresthesias along with occasional to frequent pain and stiffness, necessitating palliative care.
Prognosis
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5. Guarded - The patient’s condition is not expected to improve in the near future. They may expect to have continued muscle weakness and sensory deficit. Palliative and/or supportive care will be warranted for symptomatic relief and some improvement of function.
6. Unstable - Patient has not responded to the treatment trial and demonstrates evidence of deterioration. The likelihood of recovery with conservative care does not appear promising at this time. Surgical consult would be advisable.
Prognosis
▪ Start by determining your best case scenario
▪ Identify the stages or phases of care▪ Decide the number of visits
▪ Determine what services you typically perform for each stage▪ Be specific e.g. trigger point therapy vs. manual therapy
▪ Times per week and number of weeks
▪ Identify the rationales for each service provided
Set up a template
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Intensive Phase – 4 weeksCMT – 3x week, spine
▪ Reduce pain from 7/10 to 4/10
▪ Reduce measurable ROM restriction by 50%EMS (High Volt) – 3x week, cervicothoracic region
▪ Reduce pain reporting from 7/10 to 4/10
▪ Reduce palpable muscle spasmICE – 3x week, cervicothoracic region
▪ Reduce palpable swelling/edemaMyofascial Release – 2x week, right deltoids
▪ Break-up palpable adhesions
▪ Increase range of motion by 50%
Example
Example:
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Example:
Long-term goals: Enable patient to sit pain free for 1 hr./computer -Currently, patient can only sit for 5 minutes pain free. Also restore tolerance to normal activities of daily living.
During the Acute / Intensive stage, the following services will be
provided:
98940 - CMT 1-2 Regions consisting of diversified technique will be
performed to the Neck and Upper Back, to reduce pain from 8/10 to 4/10
and reduce measurable ROM restriction by 50%. This will be provided 3
times per week for 2 weeks.
97014 - Electrical Stimulation-2 consisting of interferential will be performed
to the Neck, specifically to the cervical suboccipital muscles,. This will be
provided 3 times per week for 2 weeks, to reduce pain reporting from 8/10 to
4/10 and reduce palpable muscle spasm.
During the Strengthening / corrective stage, the following services will
be provided:
98940 - CMT 1-2 Regions consisting of diversified technique will be
performed to the Neck and Upper Back, to improve posture, reduce
measurable ROM restriction by 50%, and reduce pain from 4/10 to 0/10.
This will be provided 2 times per week for 4 weeks.
97110 - Therapeutic Exercise (Ea. 15 Min) consisting of PNF stretching
exercises, cervical AROM, and cervical flex/phase 1, 3 sets 6 reps 6 sec
hold 28 mm will be performed to the neck, to increase strength from 3/5 to
5/5 and increase range of motion by 50%. 1 unit will be provided 1 time per
week for 4 weeks.
From the ChiroCode DeskBook
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1. Were the goals met?
2. Are there new goals?o Improve NDI from 30% to 10% by 7/1/18
3. How will care change now?o More intense home exercises?
o Fewer office visits?
o Eliminate passive modalities?
The key: show progress!
At the Re-evaluation
According to BCBSLA (Professional Provider Office Manual, June 2018):
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Daily Visit Requirements
According to Optum (Utilization Management Policy #474):
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According to another major payer, daily visit notes require the following:
1. a subjective record of the patient complaint i.e., location, quality, and intensity
2. physical findings to support manipulation in a region or segment e.g., regional/segmental asymmetry or misalignment, range of motion abnormality, soft tissue tone and/or tenderness characteristics
3. assessment of change in patient condition, as appropriate
4. a record of the specific segments manipulated 95
Daily Visit Requirements
According to Colorado’s Rule 22:
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Daily Visit Requirements
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According to a provider network in the Midwest:
1. Patient identification (name and DOB)
2. Date of encounter and visit # in treatment plan (e.g. visit 3 of 8)
3. Chief complaint/rationale for visit (NMS condition)
4. Updated patient-specific measurable subjective and objective attributes
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Daily Visit Requirements
5. Assessment of functional changes (patient specific)
6. Current diagnosis
7. Procedure specifics (service performed, location, rationale, time)
8. Plan (next treatment date, next re-evaluation)
9. Provider ID and signature, with date/time stamp
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Daily Visit Requirements
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Daily Visit Requirements
Local Coverage Determination (LCD): Chiropractic Services (L33613), page 6National Government Services, Inc.
According to Medicare:
Subjective
Objective
Assessment
Plan/Procedures
SOAP
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SOAPSubjective- in the patient’s words
• Each complaint (by location)o Region or laterality
o Severity (e.g. pain scale)
o Character (e.g. stiff, burning, tingling)
o Duration/timing (e.g. percentage of time with pain)
o Aggravating or relieving factors
• Emphasize change since last visito Patient statement of functional change (ADLs)
• “I can walk a few hundred yards further before the pain stops me.” OR “ I can sleep 3 hours before the pain wakes me up.”
• Copy/paste on more than a couple visits will look like cloning
SOAP
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SOAP
Objective- Quantifiable information• Segmental Dysfunction: PART
• Other Dx: o Palpation, ROM, stability, muscle strength/tone (97 DGs)
o Relevant ortho/neuros, if applicable
• OATs retest, if applicable
• Emphasize change since last visit
• Copy/paste on more than a couple visits will look like cloning
SOAP
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Assessment: S+O=A• Outline the phase of care (i.e. relief, corrective)
• Diagnostic statement / clinical impression
• Prognosis• Subjective progress (ADLs)
• Objective progress (exam findings)
• Barriers to recovery / aggravating factors
• Percentage completion towards specific and measurable long-term goals
• Complications and patient compliance, or lack thereof
SOAP
SOAP
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Plan/Procedures- Outline of what is next
• Procedures
• CMT (specific segments and technique)
• Modalities (type/location/time/rationale)
• DME (type/rationale)
• Therapy (type/location/time/rationale)
• Home instructions
• Visit # and anticipated date of next evaluation
SOAP
SOAP
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Subsequent Visit Requirements
Local Coverage Determination (LCD): Chiropractic Services (L33613), page 6National Government Services, Inc.
According to Medicare:
SOAP and CMS
1. History (S)
2. Physical Exam (O/A)
3. Treatment Given (P)
4. Fit within Plan (P)
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• Review of chief complaint
• Changes since last visito Following last treatment
o Immediately preceding current visit
• System review if relevant
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SOAP and CMSHistory
• Exam of area of spine involved in diagnosiso Document subsequent changes by updating NMS
exam findings for all diagnoses reported
o Full repeat of PART is not expected
o If a significant and separately identifiable exam is performed, bill an E/M code with 25 modifier
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SOAP and CMSPhysical Exam
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• Assessment of changes in patient condition since last visito Compare previous findings to current
o Evaluation is ongoing, signs and symptoms must be rechecked during the course of treatment.
o List and update diagnoses if applicable
• Evaluation of treatment effectivenesso Acknowledge progress towards goals (or lack thereof)
o “Patient is responding as anticipated as evidenced by…”
o State “Patient tolerated treatment without incident” as appropriate
o Modify treatment as necessary 113
SOAP and CMSPhysical Exam
• Chiropractic Manipulative Therapy (CMT)o List specific vertebra and technique used
o Include compensatory segments (not payable)
• Modalities and therapies (not payable)o “…as outlined in treatment plan dated 2/12/2019”
rather than listing repetitive details
• State “This is treatment 4 of 10” to let everyone know that there is a plan
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SOAP and CMSTreatment Given / Fit within Plan
113
114
9/9/2019
58
SOAP and CMS
1. History (S)
2. Physical Exam (O/A)
3. Treatment Given (P)
4. Fit within Plan (P)
Take Away
• Identify the top mistakes DCs make
o Fees schedules
oMedical necessity
oCloning
o Lousy diagnoses
o Lousy care plans
oGet a handle on SOAP and CMS requirements
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