Confused about the New Medicare LCD?

The Illinois Chiropractic Society is continually working to ensure our members have the latest information. As we announced last month, National Government Services (NGS) modified the chiropractic Local Carrier Determination (LCD) for our region, and the changes that NGS implemented are very positive for our profession.

We are receiving information from members that indicates there is some confusion surrounding the removal of the secondary diagnosis codes from the LCD. The ICS has spoken to our national liaisons and with NGS directly regarding these changes, and we have confirmed the information we previously issued and the information below.

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Important: The elimination of the secondary codes was not a mistake nor a result of any confusion. This was an intentional change that was negotiated by American Chiropractic Association representatives with NGS and CMS. This elimination was a big step forward towards parity for chiropractic physicians, as you can now utilize the correct ICD-10 code that most closely resembles the diagnosis demonstrated. There is no longer a restrictive list for secondary/qualifying diagnosis codes.

Here are some particulars for your Medicare billing practices based on the new LCD:

1. “The primary diagnosis must be subluxation, including the level of subluxation, either so stated or identified by a term descriptive of subluxation.” Therefore, the primary diagnosis must indicate subluxation, and chiropractic physicians must use Group 1 Codes as indicated in the LCD (M99.01-M99.05). This is not new and has been a requirement under the law for many decades.
2. There is no longer a specific listing of secondary (Group 2 Codes) within the LCD (All 263 code references have been removed). The result of the removal of the secondary diagnosis listing from the LCD means that our doctors can utilize the correct ICD-10 code that most closely resembles the diagnosis demonstrated.
3. Although a secondary (and additional) diagnosis code is not mandatory, The Illinois Chiropractic Society strongly urges chiropractic physicians to include any relevant secondary/qualifying diagnosis to properly reflect the patient’s condition, correctly code the documented diagnosis, protect against potential future claims reviews, and clearly demonstrate the number of conditions that we treat as a profession. As we continually aim for provider parity within Medicare, we must document and bill at the highest level. This includes documenting and billing qualifying/secondary diagnosis codes.

Please watch for more ICS releases about a continued national effort to create parity within Medicare, including treatment coverages, opt-in/opt-out laws, and within LCDs nationwide.