The OIG estimates that CMS made $358.8 million in improper Medicare payments for chiropractic services in 2013 – totaling 82 percent of Medicare chiropractic services in that period (note, however, that these findings were based on a small pool of 105 services for which Medicare paid $2,712). According to the OIG, the documentation provided by the chiropractors for the questionable services did not support medical necessity. The OIG recommended that CMS implement controls to prevent improper payments to chiropractors, including:
- Establishing edits to identify services in excess of those needed to actively treat spinal subluxation;
- Determining whether there should be a limit on the number of chiropractic services that Medicare will reimburse;
- Improving education of chiropractors on Medicare coverage requirements and modifier use; and
- Developing reliable controls to identify noncovered maintenance therapy.
In response to the report, CMS outlined steps it is taking to detect fraud, waste, and abuse, including implementing a prior authorization policy for chiropractors with aberrant billing patterns and expanding educational efforts.