I do not bill insurance; why must I follow CMS documentation guidelines?
In recent months, we’ve heard some questions about why FSOMA has been focusing on insurance issues when many APs don’t take insurance. FSOMA certainly recognizes that many practitioners do not take insurance and absolutely supports those practices. However, in accordance with our mission and purpose, FSOMA is committed to delivering necessary updates to advance the practice of ALL Florida acupuncturists. Insurance is currently one of the hottest topics with the most confusion among our members, which drives this topic to the forefront of our attention, resulting in increased publicity.
Recently, acupuncturists who accept insurance have been running into significant roadblocks, similar to many other medical providers, who find it challenging to get adequate reimbursement. The most current issue is that some of the major policies have started denying Evaluation and Management (E&M) CPT codes and, in some cases, recouping them back. The main reason for this denial is a lack of awareness from the Acupuncturists about recent changes from time-based E/M to Medical Decision Making (MDM) based documentation and coding according to the 2021 Centers for Medicaid & Medicare Services (CMS) guidelines.
Another reason for increased attention to acupuncturist documentation surfaced after audits completed by VA and United. The VA audit determined that 76% of documentation provided by outsourced acupuncturists does NOT support the billed claims, including 19% of the cases that had no documentation at all! These practices led to enormous recoupment demands and the engagement of the Department of Justice, accusing acupuncturists of fraud.
Mandates for proper documentation do not finish with insurance; as a matter of fact, lack of appropriate documentation is the most common reason for fines, orders for remediation of substandard documentation, and loss of license in Florida. Even if the initial complaint to the Florida Acupuncture Board had nothing to do with documentation, it is inadequate documentation that leads to the inability to defend yourself. This can include fines and remediation for poor documentation.
The FSOMA’s Insurance & Best Practices Committee is currently working on a document that showcases many insurance companies’ reimbursements offered. With two goals in mind: 1st - to create marketing material (including information about insurance payments for acupuncture and referral guidelines) for other healthcare providers to facilitate referral to FL acupuncturists; 2nd – to equip FL acupuncturists with better information to determine if accepting insurance is right for them. An interesting fact we’ve discovered so far is that Workers’ Compensation will have rates higher than cash fees for our services in 2025. Look for a webinar soon on how to get into that system as a provider.
FSOMA supports everyone’s style of practice, whether it’s cash or insurance billing based or everything in between. Our medicine is not a one-size-fits-all practice, just as there is no one acupuncture style. However, documentation standards are not just for insurance billing. The CMS guidelines outline the content and format of documentation, which are mandatory for all providers (including acupuncturists), whether you bill insurance or not.
We have offered two classes on Documentation compliance: the first by Galina V. Roofener and the second by Amy Sear. Both these APs have extensive experience with the medical system and know the basics of good documentation. For more resources on documentation, visit this web page or reach out to [email protected]. Together, we can build a stronger, more resilient acupuncture community where we can all thrive and succeed. We encourage all APs to be trained in professional documentation that is compliant with best practice standards.
To Review: Why Documentation Matters (3 of these 4 have nothing to do with insurance.)
- Legal Protection: Thorough and accurate documentation acts as a safeguard for practitioners. If a patient raises a complaint, an attorney or BOA will audit your documentation, and well-maintained records will provide evidence of your adherence to best practices and legal requirements.
- Quality of Care: Good documentation isn’t just about compliance; it’s also about improving patient care. Clear records of treatment plans, progress notes, and patient interactions ensure continuity of care and help tailor future treatments.
- Insurance Reimbursements: Insurers require specific documentation to process claims. Having detailed and organized records facilitates timely reimbursements and reduces the likelihood of denials. This includes clear indications of medical necessity, treatments provided, and support for charges rendered. Proper documentation will protect you from payment recoupments and fraud accusations.
- Streamlined Processes: Efficient documentation practices can save time in your practice. By developing a standardized approach to record-keeping, you can reduce administrative burdens and focus more on patient care.
As part of FSOMA’s Best Practices Initiative, we encourage all acupuncturists—whether you accept insurance or not—to prioritize robust documentation practices. By doing so, you protect your practice and your patients. As we navigate these challenges together, let’s commit to upholding our field’s highest standards of professionalism and care.
For more resources on documentation and billing practices or to learn more about FSOMA’s initiatives, visit this web page or email [email protected]. Together, we can build a stronger, more resilient acupuncture community.
Galina Roofener, LAcFSOMA President