Believe It or Not

Chiropractic Compliance Consultants, Inc. (CCC)

· When starting CCC, Mr. Osborne was told by a number of investigators he had worked with over the years that he had gone to the ‘dark-side’ by working with chiropractors. His response: assisting providers, regardless of discipline, who want to take steps to ensure they comply with the laws & rules is not a bad thing but is THE RIGHT THING, and he is proud to be doing the right thing!

· Some practice builders instruct clients not to use our services—calling us practice killers. This doesn’t make any sense! We are Practice Savers keeping practices from getting crushed by investigations, loss of license, civil judgments, fines &/or prison — helping practices make more money and keep more of it without having to pay it back or pay legal fees to defend misconduct!

· A chiropractor, in his compliance seminars for other chiropractors, blames Mr. Osborne for giving him bad advice that resulted in his going to prison. For those who have heard, or will hear, this chiropractor bantering of Mr. Osborne’s name Click here to Unlock the Truth...

· An unidentified International Association of Special Investigative Units (IASIU) member attending Mr. Osborne’s presentation at the 2004 National Health Care Anti-Fraud Association (NHCAA) annual convention on the “Next Generation of Multidiscipline Practice Fraud” critiqued his presentation by asking the NHCAA why they would allow Mr. Osborne to be a presenter after he had attacked the IASIU—referring to his article National Insurance Fraud Seminar Focuses on Chiropractic? This article did not attack the IASIU but only pointed out the inaccuracies of information provided by speakers at the their 2003 annual training conference so that readers could be better informed to enhance successes on combating health care fraud.

· Mr. Osborne informed a consultant providing compliance services that prior to their conducting practice audits for health care professionals that they ensure their client retain legal counsel and that the audit be performed ‘only’ under the direction and supervision of the client’s attorney because 1) it allows the provider client a level of protection from outside investigative entities demanding the consultant’s audit report should they learn of the audit, and 2) it allows the provider client to obtain the audit report from their counsel who had the opportunity to review the audit findings and provide legal advice on responding to (substantiated) misconduct identified. Unfortunately, the consultant did not employ such a requirement prior to conducting practice audits and found themselves in federal court, relevant to one particular client, faced with demands by federal law enforcers for the ‘unprotected’ audit report.

· An attorney writing in a chiropractic periodical reported hearing a scary story from a chiropractor that the chiropractor hired a consultant to conduct an audit of his practice, and on completion of the audit the consultant demanded a low five-figure payment to ensure compliance and implementation of recommendations. The chiropractor declined to pay for the extended services and several months later the chiropractor was contacted by the government focusing on the same problems highlighted by the consultant. The problem with this story is that no substance is provided to allow readers to evaluate the validity of the events claimed. Another PROBLEM is that it fails to mention that frequently providers only seek out audit/compliance services after they suspect or know that they are being investigated! However, I suspect that the purpose of the attorney’s article is to let health care providers know that they should exercise appropriate due care prior to, during and after their decision to audit their health care practices! Click here for more stories

· In a late October 2008 tele-conference with state and insurance investigators an executive from a southern state chiropractic association reported that most of the fraud committed by chiropractors is perpetrated by chiropractors employed in clinics owned and operated by non-chiropractors. This executive went on to report that lay-owned clinics account for 80–90% of chiropractic fraud, and that these non-chiropractors prey on chiropractors just out of school saddled with large student loan debt who will do whatever they are told. Problem with what this executive says is: 1) The chiropractic regulatory board in this southern state indicates that there is no evidence to support the executive’s assertion that lay-owned chiropractic clinics account for most of the fraud committed by chiropractors. 2) Numerous states do not allow for non-chiropractors to own chiropractic clinics and these states have found that they are not immune from chiropractic fraud. 3) Chiropractors saddled with large student loan debt inclined to engage in unlawful activity to pay their bills are just not only employed in lay-owned clinics but are employed in clinics owned and operated by other chiropractors, as well as running their own practice. 4) Health care consumers in this southern state are probably less concerned about who owns the chiropractic clinics then they are about quality of care issues brought on by chiropractors delegating the administration of provider services to non-providers, and chiropractors not being required to be on premises to supervise non-licensed staff administering health care services.

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Believe It Or Not

Chiropractic Compliance Consultants, Inc., 18065 238th Street, Tonganoxie, KS (913)369-9000, (913)845-2769 Fax

18065 238th Street, Tonganoxie, KS 66086

913-369-9000, 913-845-2769 (Fax), cccpfc@gmail.com

CCC is just what the doctor ordered!