by Marty Kotlar, DC, CPCO, CBCS

President of Target Coding

Question: I just received a letter from an insurance company requesting copies of exams, SOAP notes and financial records on 14 patients. I am concerned…some of my notes are not good and on some dates of service I do not have any notes at all. What should I do?

Answer:  I have put together a checklist for you – here you go:

  • Check the names of the patients listed in the letter you received from the carrier. Are these patients your patients?  I have seen providers receive correspondence from insurance carriers that were not intended for them to receive.
  • Pull the patient charts and start to review them. Do the dates of service in your chart notes coincide with the dates of service that the carrier is requesting?  Let’s assume the answer is yes as we continue with this list.
  • After your initial chart review, ask yourself if you’ll be able to gather all of the requested information by the request deadline. Typically, carrier’s request patient charts to be submitted within 30 days of the date on the letter you received.  This may not be reasonable.  Therefore, call the carrier and request an additional 30 days to submit the requested information.
  • If you make this call, you may now have an opportunity to speak to the lead investigator. Do not provide any information to the investigator that can hurt you.  Some attorneys may not recommend you speak to the investigator at all.  However, I do not see anything wrong with asking the investigator for an extension.  I also do not see anything wrong with asking the investigator why you were chosen for this chart review.  Again, do not volunteer information that can link you to any wrongdoing.
  • After copying all of the requested information, I typically recommend providing the carrier with a “treatment summary” for every patient. A summary of the care you provided helps the carrier understand your clinical approach.  However, treatment summaries are not required.  If you think your SOAP notes and treatment plans are sufficient, it’s not necessary to create treatment plans, they can be time consuming.
  • Many insurance carriers post chiropractic “position statements” on their websites. Please make sure to read these position statements from all the carriers that you bill.
  • Make sure to learn as much as possible about establishing medical necessity, evaluation and management, CPT-ICD code linking and patient goal setting.

Some chiropractors attain the services of an attorney as soon as they receive any type of records request from an insurance carrier.  I do not see any downside to doing this.  There’s nothing wrong with speaking to an attorney about your situation.

The most important thing to do is STAY CALM.  Just because you receive a records request doesn’t mean you did anything wrong.  After you submit the requested information, no news is good news.  You may never hear from them again.


Dr. Marty Kotlar is the President of Target Coding. Over the last 12 years, he has helped hundreds of chiropractors, acupuncturists, physical therapists and massage therapists with compliance as it relates to billing, coding, documentation, Medicare & HIPAA. Dr. Kotlar is certified in compliance, a certified coding specialist, a contributing author to many coding and compliance journals and a guest speaker at many state association conventions. He can be reached at 1-800-270-7044, website – www.TargetCoding.com, email – drkotlar@targetcoding.com.

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