Focused On Health Care Law

Chiropractors cautioned to be careful in medically integrated practices

On Behalf of | Jun 15, 2021 | Stark Law and Anti-Kickback Statute compliance |

Like other medical professionals, chiropractors are aware of the significant benefits to patients when health care is provided by a medically integrated practice.

“Medical errors are minimized, unnecessary tests avoided, prescription painkillers reduced,” chiropractor Jesse Cooper told the American Chiropractic Academy in 2019.

Consequences can be serious

However, there are strict services and billing guidelines to be observed and potentially serious legal consequences when integrated practices are not set up properly, according to a recent article by chiropractor and medical compliance officer, Ray Foxworth.

He writes in the current issue of Chiropractic Economics that a multidisciplinary medical practice should assume that audits will take place and prepare accordingly.

Advice about attorneys

Chiropractor Mark Sanna – who also authored a piece in CE – writes that medically integrated practices should “retain local legal counsel familiar with the group practice health care laws and regulations of the state in which the practice will be established.“

Sanna notes that “while successfully operating a MDP can be rewarding, those rewards can quickly disappear should the chiropractor and other professionals involved not adhere to the most stringent policies and procedures.”


Foxworth writes that medically integrated practices “must be aware” of the federal Anti-Kickback Statute that forbids healthcare providers from exchanging or offering to exchange something of value in return for Medicare or Medicaid referrals.

Foxworth writes that “many providers are not aware that the AKS can be triggered by not charging for each and every service you provide.”

He writes that a chiropractor in an integrated practice might have a patient referred by a nurse practitioner for evaluation and cautions that the DC “should not offer (the evaluation) at no charge or at a reduced fee just because they saw your nurse practitioner first.” Either one could be considered an inducement violation.

Harsh punishment

“Conviction on even one charge can result in five years in jail, $25,000 in fines, and exclusion from the right to participate in any federal health care program (not just Medicare or Medicaid),” Foxworth writes.

His point is clear: the cost of an Anti-Kickback violation is far greater than the cost of retaining a health care law attorney.