www.njchiropractors.com I 17 MEDICARE Q&A Q  Does Medicare have a requirement that an examination must be per- formed every 30 days? A  The Novitas-Solutions Medicare policy does not have a specific time require- ment for re-examinations. However, the progress notes should show that a reasonable expectation of clinical improvement is being achieved. This may be accomplished on a visit-to-visit basis or at pre-determined intervals set forth in the treatment plan Q  May a Medicare record be amended or corrected? A  According to the Medicare Program Integrity Manual, “All services provided to beneficiaries are expected to be documented in the medical record at the time they are rendered. Occasion- ally, certain entries related to services provided are not properly documented. In this event, the documentation will need to be amended, corrected, or entered after rendering the service.”  “Regardless of whether a documen- tation submission originates from a paper record or an electronic health record, documents submitted that have amendments, corrections or addenda must:  1.  Clearly and permanently identify any amendment, correction or delayed entry as such, and  2.  Clearly indicate the date and author of any amendment, correction or delayed entry, and  3.  Clearly identify all original content, without deletion.” Paper Medical Records:  When correcting a paper medical record, these principles are generally accomplished by: 1.  Using a single line strike-through so the original content is still readable, and 2.  The author of the alteration must sign and date the revision.  Amendments or delayed entries to paper records must be clearly signed and dated upon entry into the record. Amendments or delayed entries to paper records may be initialed and dated if the medical record contains evidence associating the provider’s initials with their name. For example, if the initials match the first and last name of the practitioner documented elsewhere in the medical records including typed or written identifying information, the reviewer shall accept the entry. Electronic Health Records (EHR):  Medical recordkeeping within an EHR deserves special considerations; however, the principles specified above remain fundamental and necessary for document submission. Records sourced from electronic systems containing amendments, corrections or delayed entries must: 1.  Distinctly identify any amendment, correction or delayed entry, and 2.  Provide a reliable means to clearly identify the original content, the modified content, and the date and authorship of each modification of the record. 3.  If the medical documentation con- tains potentially fraudulent entries, it may be referred to the audit contrac- tor investigating fraud and abuse. Q  I was asked to submit documentation for a Medicare CERT audit; what information are they asking for? A  They are looking for all documentation for the episode of care in which the date of service in question lies. This would typically be the date that you have in Box 14 of the 1500 form, since that is the date you documented that the condition first began.  Some items to include in the submis- sion of the documentation include: 1.  Original initial evaluation - (initial visit/exam notes)  2.  Diagnostic test results/reports, including imaging reports, physical/ occupational therapy notes, etc. 3.  Treatment records - include legible progress/office notes with any available abbreviation legend or abbreviation key, attestation of medical record missing signature entries and/or authentication of legible identification of the provider services, type and location of the specific anatomical levels of manipu- lation treatment/supportive notes 4.  Any Advanced Beneficiary Notice of Non-coverage (ABN) issued to the beneficiary for each date of service and each specific service an ABN was issued 5. Treatment plan 6.  For electronic health records, send a copy of the electronic signature policy and procedures that describe how notes and orders are signed and dated. Validating electronic signatures depends on obtaining this information. 7.  BEFORE YOU SEND - Check for signatures on office/progress notes or other medical record documenta- tion. If the signature(s) are missing or illegible, send a completed signature attestation (find a sample attestation at https://www.certprovider.com/). If the signature(s) are illegible, you may also send a signature log. Q  With the new federal budget that was recently signed, are we still subject to the sequester fee? A  The Bipartisan Budget Act of 2018 does not alter the separate seques- tration reduction of two percent for payments under Medicare and, in fact, extends those reductions through 2027. Richard C. Healy, DC, CCSP, is the treasurer and Medicare consultant for the ANJC. A New Jersey Medicare Carrier Advisory Committee delegate and a Certified Chiropractic Insurance Consultant, Dr. Healy is a graduate of New York Chiropractic College and has been in private practice in Dumont for more than 35 years. By Dr. Richard C. Healy ANJC Medicare Consultant