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How Long Should I Keep Records on File For Medicare Purposes?

There is a lot of confusion in the provider community about how long to keep records on file.  There are several types of records discussed.

Medical documentation is the notes/test results pertaining to services provided to the patient.  Medicare uses this documentation to verify the provider performed the service billed and that the services were coded correctly and medically necessary.  Accurate and complete records are a worthwhile investment and can save time and money in the event of an audit.  Providers should store records in a format that makes it easy for retrieval.  If a provider has to go through thousands of boxes to find the record in question, it will cost time and money.

1. If Medicare requests documentation, the entity Medicare paid for the service is the entity responsible for supplying the documentation.  This means that if a provider has billed and Medicare has reimbursed for a visit to a patient in the hospital, nursing facility, etc. or for a purchased diagnostic service, he/she should verify that the documentation to support that service is available.  Medicare has received several different types of responses to requests for medical records including "that's the hospital, you'll have to contact them," "I don't know where the records are, I just started working here last week," and "records, what records?"
2. Notification of any payments from any insurance primary to Medicare.  This includes the Explanation of Benefits and any appeals the provider may have made pertaining to the claim.
3. Payment record from Medicare.  This includes Remittance notices, overpayment notices, record of payments back to Medicare and any appeals taken on specific claims.
4. Provider Enrollement Information.  This indicates that a provider is who they say they are and is located where they claim to be.  The enrollement information also indicates if the entity is a group and that the members of the group really do exist.

Providers who sign the Electronic Data Interchange (EDI) Enrollement from agree to keep medical records no less than 6 years, three months after Medicare has paid the claim.  This means that if the claim for a date of service 1/1/05 and completed processing on 6/30/05, then records should be kept until at least 9/30/11.  Medicare recommends that providers keep records on file for at least 7 years unless state statute or your own comfort level tells you otherwise. 

Medicare has received questions on record retention when the provider retires, leaves a practice, or passes away.  The same information listed above applies.  In some cases, a provider retiring will sell his/her practice to someone else.  The retiring provider should verify that they have access to the records should that become necessary.  When a provider leaves a group practice, the group verifies that records are accessible.  When a provider passes away, the estate verifies that records are available for the time-frames listed above.

How Do you Deal with a Patient who Regularly Misses Appointments!

The easiest way to keep patients on schedule is to have them re-schedule.  The health needs of the patient are the basis for their schedule, and to keep the care plan on track, it is vitally important that missed appointments be made up.  It is best to re-schedule a missed appointment for the same day if possible.

Be careful not to say that the patient "missed" their appointment as this is sugggesting that the patient is in the wrong.  The patient is NEVER wrong!  There are some instances when the clinic schedule might be misleading.  It may be that the patient is in the appointment book more than once or came in for an unscheduled treatment earlier.  Always use a caution in approaching this aspect of your relationship with the patient.  When patients do not appear for their scheduled appointments, be prepared to accept their excuses, and not argue in anyway, but work to facilitate the most rapid rescheduling.  Remember, getting them back in is the point.

Staff should be the contact point for all discussions regarding scheduling.  It is not necessary for the doctor to get involved in the day to day scheduling issues.  Remember when leaving messages or sending reminders to be conscious of HIPPA concerns and patient confidentiality issues.  Here are some points to consider and some possible responses on the part of the clinic staff:

• To Busy- The patient says he/she is too busy to take time to come in at all this week for a visit.  She says she will come in when things slow down a bit.   CA Response: "I understand (pause).  I know you are busy, but we would hate to see you lose the progress you've made so far.  The doctor made recommendations for your visits to give you the maximum amount of correction.  Why don't we schedule a consultation with the doctor?  Maybe he can discuss a way to fit your visits with your schedule as to not interrupt your progress.  Can the doctor call you at home tomorrow around noon?"  Sometimes the mere suggestion that the doctor will be calling them is enough to get the patient to come in.  Their hesitation may mean that the patient is trying to see if you really believe in the series of care as much as discussed, or that they simply need to be reminded of their responsibility to their health.  Being sincere but firm will get them back on track.   The doctor should be notified if a patient is indecisive about their care.
• Refusal To Be Called - The patient says she missed her appointment because she needs to go to the beauty palor to get her hair and nails done before her relatives come into town.  She says she'll try to come in later in the week.  She insists that your office NOT call her, she'll call you.    CA Response: "Mrs. Jones, would it be alright if the doctor gives you a call?"  If she says no, tell her nicely that you will give the message to the doctor.  If this is the case, or if the doctor is unable to reach her by phone, you will need to release this patient by mail.
• Forgot - "Oh, I forgot that I had an appointment today.  There are too many things to keep track of!"     CA Response: "I understand.  But don't forget how important it is to get your care.  We'll get you set up for tomorrow to make up for that lost appointment today, unless you can come in later this afternoon.  If you do decide to come in today though, please don't forget."
• No Transportation - "I got a flat tire and it's just been a big ordeal."      CA Response:  "Well, we understand.  We'll set you up for tomorrow to make up for the lost appointment today, unless you can come in later this afternoon.  We don't want to break down like your car did." 
• Discouraged Patient - "I don't think it's working for me.  I don't feel any better than when I started."     CA Response:  Well, we need to understand further as to why you are not improving as quickly as you feel you should.  Sometimes after long periods of having these types of problems, it takes longer than usual for you to see results.  We may further evaluate your care today when you come in for your adjustment.  I will let the doctor know you are not improving as quickly as you would like."

These are just a few possible scenarios, but the excuses can be very diverse and range from genuine conflicts to the most incredible and frankly uhnbelievable excuses.  In the end, it's your educating the patient on the need for care, the nature of chiropractic care and the profound health implications of the chiropractic adjustment process that can help you cut through the excues process by instilling a sound understanding of the powerful clinical relevance of care.  In the end, like so many things in health care, education and understanding are your best tools to address scheduling problems and issues.      

ICA Proven Strategies, Jan. Og