Challenges of Offering Both Physical Therapy and Chiropractic Services in same facility Under New York No-Fault Insurance

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In New York State (NYS), automobile accident victims are often covered under No-Fault (NF) insurance, which provides reimbursement for necessary medical treatments related to accident injuries. Physical therapy and chiropractic care are both recognized as valid treatment modalities under No-Fault. However, many patients discover it can be extremely difficult to find a single No-Fault practice that legitimately offers both physical therapy (PT) and chiropractic treatment. Below is a detailed explanation of why this challenge exists, as well as the specific requirements that must be met to maintain compliance with No-Fault regulations.

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1. The Core Issue: Conflict of Interest in Billing

Under New York No-Fault regulations, insurers carefully scrutinize billing practices to ensure treatments are medically necessary and billed correctly. One key point is that billing for the same ICD-10 diagnosis codes on the same date of service can create a conflict of interest. If a facility that provides physical therapy also tries to provide chiropractic services for the same injury and same patient on the same date, it could appear as “double billing” for essentially the same service or same condition.

• Why does this matter?
  The No-Fault system is designed to prevent overutilization and fraudulent billing. When PT and chiropractic services overlap too closely (same date, same diagnoses, same facility), it raises red flags. Insurance carriers want to ensure each type of service provided is distinct and necessary, and that the patient does not receive duplicative treatments.

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2. Specific Requirements to Resolve This Conflict

Despite the billing challenges, it is still possible for a patient to receive both physical therapy and chiropractic services under No-Fault, so long as certain requirements are met. Here are the key steps:

1. Referral to a Chiropractor by an MD or DO
   • What does this mean?
     Under NYS law, some services—especially chiropractic—often require a formal referral or prescription from an MD (Medical Doctor) or DO (Doctor of Osteopathic Medicine) when operating under No-Fault. This document legitimizes the medical necessity of chiropractic care in addition to physical therapy.
   • Why is it necessary?
     The goal is to ensure there is an independent medical opinion validating the need for chiropractic intervention. This protects the patient, the insurance carrier, and the providers from claims of unnecessary or redundant treatment.
2. The Chiropractor Must Have His or Her Own Professional Corporation (PC)
   • What does this mean?
     In New York, licensed professionals like chiropractors often operate under a professional corporation (PC) or professional limited liability company (PLLC). This legal structure helps delineate liability and compliance for billing, ensuring that one professional’s claims do not affect another.
   • Why is it necessary?
     A separate PC helps maintain a clear distinction between the chiropractic practice and the physical therapy office, reducing any perceived conflict of interest in billing. If the same professional entity provides both PT and chiropractic, it complicates the billing and ownership structure, making it harder to prove services are distinct.
3. Chiropractic Treatments Must Occur on Separate Dates from Physical Therapy
   • What does this mean?
     If a patient receives physical therapy on a given day, the chiropractic service for the same injury cannot be billed on that exact date under the same diagnosis codes. Instead, the patient should schedule chiropractic treatment on a different day.
   • Why is it necessary?
     This separation helps demonstrate that each type of service—physical therapy versus chiropractic—addresses the patient’s needs in a discrete and non-duplicative manner. It prevents the appearance of “double billing” for the same codes on the same date.
4. Billing Must Be Separate
   • What does this mean?
     The chiropractor must use their own billing department or service. The physical therapy facility cannot bill on behalf of the chiropractor for the same ICD-10 codes.
   • Why is it necessary?
     Different billing streams help prove that each professional is independently responsible for their claims and documentation. This ensures transparency, allowing the insurance provider to see exactly who provided which service, on what date, and for which diagnosis.

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3. Practical Challenges for Integrated Practices

A. Financial and Administrative Complexity

Establishing a practice that offers both PT and chiropractic while following these guidelines involves navigating a host of administrative, legal, and financial hurdles. It may require:

• Maintaining separate corporate entities.
• Hiring or contracting with additional billing specialists who understand No-Fault rules.
• Coordinating patient schedules to avoid overlapping services on the same date.

B. Regulatory Oversight and Audits

No-Fault insurers frequently audit providers. An integrated practice offering PT and chiropractic can expect more intense scrutiny. Auditors look for:

• Separate documentation demonstrating distinct necessity for each treatment.
• Proper referral and prescription protocols.
• Different treatment dates for the same ICD-10 codes.

C. Liability Concerns

When an office offers multiple modalities, there is a higher risk that billing may inadvertently overlap. Any mistakes might lead to denials, requests for refunds, or even allegations of insurance fraud. For smaller practices, this risk often outweighs the potential benefits of providing both services under one roof.

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4. Patient Considerations

Despite the difficulty, patients can absolutely benefit from both physical therapy and chiropractic treatments after a car accident. If each modality is medically necessary and properly documented, the patient can experience:

• Pain relief from chiropractic adjustments, which can restore spinal alignment and joint mobility.
• Functional improvement from physical therapy exercises, which can strengthen muscles and improve range of motion.

Key Takeaways for Patients Seeking Both Services Under No-Fault:

1. Request a referral from your MD or DO explicitly for chiropractic care.
2. Be prepared to visit two different locations if you can’t find a single integrated practice that meets the compliance requirements.
3. Verify the chiropractor’s billing process to ensure they operate under a separate PC and have a clear line of communication with your physical therapy provider (if integrated in the same building).
4. Separate your appointments so PT and chiropractic do not occur on the same day for the same diagnosis.
5. Keep thorough records of visits, referrals, and any communications with the insurance company to avoid potential claim denials.

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Finding a No-Fault physical therapy office that also offers chiropractic services in New York State is challenging primarily due to strict insurance regulations aimed at preventing duplicate billing. Under NYS No-Fault, when the same ICD-10 codes are billed on the same date for the same patient by a single entity, it creates a conflict of interest. Compliance involves ensuring separate referrals, maintaining a distinct professional corporation for chiropractic services, scheduling treatments on different dates, and billing independently.

While this may seem burdensome, these rules protect both patients and providers from billing disputes and help maintain transparency. With proper planning, organization, and compliance with the guidelines outlined above, patients can indeed receive the benefits of both physical therapy and chiropractic care under No-Fault—just be aware that finding a fully integrated practice can be difficult due to the complexity and cost involved in meeting these stringent regulations.