Accessing and understanding billing requirements for chiropractic Medicare services can be tricky. The American Chiropractic Association completed a research study for 2024 and claimed 30% of chiropractic services submitted for the initial claim are denied. This shows the need for effective denial management strategies to cut down on the expected overhead and the disruptions to the expected cash flow. On a positive note, the Q3 2025 CMS report underscores the significant cut, 25%-40%, that practices who implement organized billing practices achieve.
Are you having trouble with Medicare chiropractic billing denials? Talk to chiropractic specific billing professionals.
What Medicare Actually Covers for Chiropractic Care
Medicare will cover only manual spinal manipulation for subluxation. Subluxation occurs when associated vertebrae are restricted in their movement while maintaining contact. Generally, 68% of common chiropractic services do not meet Medicare reimbursement criteria.
Covered: Hands-on spinal manipulation for documented subluxation at specific vertebrae.
Excluded: All diagnostic imaging, all therapeutic modalities (ultrasound, electrostimulation, etc.), all soft tissue work, acupuncture, nutrition counseling, lab test, evaluation visit, maintenance care, and all other soft tissue work documented as therapeutic.
Patients are required to pay 20% of Medicare-approved fees after they meet their annual Part B deductible of $240.
Choosing Your Medicare Enrollment Status
Enrollment decisions directly affect practice revenue and patient costs. For practices seeing 100+ Medicare patients monthly, this choice can impact annual revenue by $15,000-$30,000.
| Enrollment Type | Your Reimbursement | Patient Responsibility | Revenue Impact |
| Participating | 100% of approved amount | 20% coinsurance only | Baseline revenue |
| Non-Participating | 95% of approved + limiting charge option | Up to 35% (20% + 15%) | +9-12% potential |
| Opt-Out | Set your own fees | 100% out-of-pocket | Unrestricted fees |
Participating (73% of practices): 100% of approved rates; patients pay only 20% coinsurance.
Non-Participating: 95% of approved amounts with limiting charge option up to 15% above approved fees, generating 9-12% more revenue per visit.
Opt-Out: Complete Medicare exit via two-year agreement; set your own fees with private patient contracts.
CPT Codes for Chiropractic Treatment
Medicare recognizes three codes based on regions treated. 2025 rates show declining trends:
| CPT Code | Regions Treated | 2025 Rate | Change from 2023 |
| 98940 | 1-2 regions | $26.75 | -2.1% decline |
| 98941 | 3-4 regions | $38.71 | -1.3% decline |
| 98942 | 5 regions | $50.48 | -1.9% decline |
Bill only for regions where patients present specific complaints with documented subluxation. Document chief complaint, secondary symptoms per region, objective examination findings, and specific subluxation characteristics at each level.
Modifier Requirements: Essential Claim Components
Improper modifier use is one of the most common mistakes in chiropractic billing that generates 31% of chiropractic claim denials.
AT Modifier: Required on every manipulation code. Identifies active treatment and distinguishes from maintenance care. Without it, Medicare automatically rejects claims.
GA Modifier: For services likely denied with a signed Advance Beneficiary Notice (ABN).
GY Modifier: For services Medicare never covers (e.g., diagnostic imaging).
GX Modifier: For voluntary ABNs when services exceed frequency limits or transition to maintenance care.
Creating Audit-Resistant Documentation
Chiropractic audits increased 47% from 2022 to 2024, with inadequate documentation cited in 89% of payment recoveries. Average overpayment recovery: $47,000 per audited practice.
| Documentation Issue | Audit Recovery Rate | Average Recovery Amount |
| Missing subluxation demonstration | 89% | $18,500 |
| Inadequate progress notes | 76% | $12,300 |
| No treatment plan on file | 68% | $9,800 |
| Failure to document re-evaluations | 61% | $6,400 |
Primary Diagnosis: Every claim needs an M99 subluxation code first: M99.01 (Cervical), M99.02 (Thoracic), M99.03 (Lumbar), M99.04 (Sacral).
Secondary Codes: Include neuromusculoskeletal conditions like M54.2 (neck pain), M54.5 (low back pain), M54.41 (right-sided sciatica).
Proving Subluxation: Objective findings document—static palpation (changes in tissue texture), motion palpation (restricted movement), range of motion versus normal values, muscle strength, and posture. Specific measure- “cervical rotation limited to right 40 degrees versus normal 80 degrees.”
Treatment Plans: Functional improvement goals, visit frequency rationalization, duration expected, goals and measures outcomes, and planned re-evaluation dates.
Progress Notes: For Medicare, re-evaluation shows objective improvement every 12 visits or 30 days, continues subluxation, and goals and functional gains to explain progress.
The Medicare Claims Submission Process
- Systematic protocols to reduce denials by 34%:
- Confirming Eligibility: Part B coverage and deductible status and secondary insurance
- Final Documentation: Same day SOAP with subluxation evidence and notes minimums.
- Apply correct medical billing codes: CPT, M99 (primary diagnosis), sub secondary, AT modifier, GA/GY/GX if relevant.
Common Denial Reasons and Prevention Strategies
Analysis of 10,000+ Medicare claims from 2024 reveals seven categories. Percentages reflect how often each issue appears (exceeds 100% as claims often have multiple issues):
| Denial Reason | Frequency in Denied Claims | Impact |
| Medical Necessity Not Established | 38% | Highest denial category |
| Missing or Incorrect Modifiers | 31% | Most preventable |
| Insufficient Subluxation Documentation | 19% | Requires template improvement |
| Incorrect Primary Diagnosis Sequencing | 17% | Software validation needed |
| Frequency Limits Exceeded | 12% | Patient communication gap |
| Timely Filing Violations | 9% | Process automation needed |
| Duplicate Claims | 7% | Tracking system issue |
Medical Necessity (38%): Journal of Chiropractic Medicine (2024) research shows practices documenting specific functional limitations with quantifiable measures experience 42% fewer denials. Use standardized outcome assessment tools.
Modifiers (31%): A 2025 billing compliance study found automated verification systems reduce this category by 87%. Implement automated attachment and monthly audits.
Subluxation Documentation (19%): Use standardized templates with specific motion palpation findings and baseline comparisons.
Primary Diagnosis (17%): Always list M99 first. Use software validation to check diagnosis order.
Timely Filing (9%): Submit within 30 days; set automated reminders at 300 days post-service.
Maintenance Care vs. Active Treatment
According to a 2024 OIG audit, 64% of overpayments to chiropractors were due to billing for maintenance care as active treatment after maximum benefit has been reached. Note that Medicare pays only for active treatment of subluxations when there is expected functional improvement, not for maintenance care. The 12-Visit Re-Evaluation Rule also stipulates that every 12 visits or 30 days, a reassessment must be performed which must show at least 15% improvement and revised goals. CMS data indicates 78% of visits denied beyond 12 visits for ongoing medical need. When maximum benefit is reached, issue an ABN, get patient signatures, and stop billing Medicare.
Key Takeaways for Billing Success
Effective billing strategies decrease denials by 34% and increase the speed of payment by 14 days:
- Always apply the AT modifier for codes 98940-98942 (reduces 31% of denials).
- Document the subluxation as the primary diagnosis with evidence (it prevents 38% of medical necessity denials).
- Re-assess patients every 12 visits (this avoids a 78% denial rate beyond this threshold).
- Move to maintenance care with signed ABNs when the situation calls for it.
- Bill within a 30-day window (you will see payment 14 days faster).
- Train on modifiers and documentation every 3 months (this decreases coding errors by 65%).
Ready to Optimize Your Medicare Billing?
MedLife billing specialists help with chiropractic billing services. Our team of specialists is always up to date with Medicare billing requirements, so you can care for your patients while we take care of your billing.