Follow This 9-Step Action Plan for the Health of Your Practice

Question: “Dr. Kotlar, I want to make sure I’m doing everything right from a compliance standpoint. What do you recommend?”

Answer: I am a frequent speaker at many chiropractic conferences nationwide and one of the most common statements I hear attendees say is that they want to make sure they’re doing everything right. My typical response is “make compliance a priority as it relates to billing, coding and HIPAA.”

Nobody’s perfect. The goal is to make good faith attempts to get compliant.

What steps have you taken recently to get compliant?

Example: When was the last time you did a “self-test” on your SOAP notes? When was the last time you calculated the amount of money you collect from the insurance company you bill the most? Which insurance companies pay you the most? If you are collecting more than 35% of your income from one insurance company, then special attention should be placed on this health plan.

Follow the below 9-Step Action Plan, just in case Blue Cross/Blue Shield, Optum, Cigna, Aetna or Medicare comes knocking on your door:

Step 1: Get pro-active.

Step 2: Review all new patient paperwork.

Step 3: Get all patient forms signed such as the health history and review of systems forms, assignment of benefits, financial policy, informed consent, HIPAA notice.

Step 4: Review the medical policies from the insurance companies you bill the most.

Step 5: Understand “what” and “why.” Your CPT codes are “what” you’re doing and your ICD-10 codes are “why.” Make sure they’re correct and justify medical necessity or else you’ll be giving money back. For example, you’ll get audited if billing 97110 and the patient does not display any ROM deficits.

Step 6: Do a self-test on your SOAP notes. Make sure you know what to look for per insurance company.

Step 7: Find out what a medically necessary SOAP note looks like and duplicate it. Also, find out what an insurance company billing compliance plan looks like and implement as soon as possible. Insurance company audits are on the rise and are going to increase in 2019. Insurance companies know that recouping money is profitable.

Step 8: Put together a simple billing policy manual that explains what you do and why you do it. Example, explain why you adjust full spine, but only bill 98940. Also, take a look at your fee schedule. If you’re billing auto insurance $250/visit and charging your cash patients only $50, then could be violating your state law on dual fee schedules.

Step 9: Conduct regular meetings specifically with staff members that do your billing, especially to the insurance companies that pay you the most money. Also, do a spot check on your billing company (if you use one). Recently I’ve seen billing companies reporting fraudulent codes and the doctor did not know until the insurance company came knocking on the door.

Let us help you S.W.A.N. (sleep well at night). Call or email Dr. John Pecora to help set up a free consultation. Email is

Marty Kotlar, DC, CPCO, CBCS is the President of Target Coding. Dr. Kotlar is Certified in CPT Coding, Certified in Healthcare Compliance and has been helping chiropractors nationwide with HIPAA, Medicare compliance, documentation and compliant cash plans for over 10 years. Target Coding can be reached at 1-800-270-7044; website –; email –

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