Year-End Compliance Checklist for Chiropractic and PT Billing in 2025

Correction and source review: September 7, 2026. Updated filing and appeal guidance, therapy thresholds, MIPS requirements, and chiropractic coverage distinctions; removed unsupported financial estimates. This article retains its original publication date and 2025 year-end context. Historical deadlines are not current filing instructions. Sources are listed at the end.

Closing out the year with a compliant billing process is essential for chiropractic and physical therapy practices to avoid penalties, recover revenue, and prepare for 2026. Medicare documentation, coding, filing deadlines, and applicable MIPS reporting requirements demand attention. Original Medicare and Medicare Advantage requirements should be checked separately; do not assume every practice or service requires prior authorization. This article provides a year-end checklist to help your practice identify billing errors, support compliance, and follow up on unpaid claims. Practice management tools can streamline these tasks, but the focus is on practical steps to keep your practice financially secure.

Why Year-End Compliance Matters

A year-end review can help identify gaps in meeting Medicare requirements. Filing and documentation errors can lead to denied claims or payment delays. The financial impact depends on the affected services, allowed amounts, and whether claims can be corrected or appealed; no fixed recovery amount is assumed here. A thorough checklist helps you close out 2025 cleanly, recover owed payments, and start 2026 strong.

Key Compliance Areas for 2025

Focus on these areas to ensure year-end compliance: documentation, claim submission, MIPS reporting, patient accounts, and 2026 preparation.

1. Review Documentation Accuracy

Complete and accurate documentation is critical for Medicare compliance and audit defense.

• Chiropractors: Verify P.A.R.T. criteria (Pain, Asymmetry, Range of motion, Tissue tone) for 98940–98942, when using physical examination to establish subluxation. Document at least two P.A.R.T. elements, including asymmetry/misalignment or range-of-motion abnormality, together with the other required findings, treatment plan, and medical necessity. A brief symptom phrase alone is not a complete record. See source 1.
• Physical Therapists: Confirm time logs for 97110 or 97140, e.g., “97110 from 10:00–10:15 AM, improving knee mobility.” Document specific treatment goals.
• Action: As an internal sampling approach, audit 10–20 claims for unsupported or missing modifiers, vague notes, and diagnosis codes that are invalid or inappropriate for the date of service.

2. Reconcile Outstanding Claims

Use year-end as an internal review target, while tracking each claim’s actual filing or appeal deadline.

• Check Unsubmitted Claims: Original Medicare claims generally must be received by the Medicare contractor within one calendar year of the service date, subject to limited exceptions. For example, a January 15, 2025 service generally has a January 15, 2026 filing deadline. December 31 is an internal cleanup target, not the universal deadline for January services. See source 2.
• Review Denials: Review adjustment and remark codes on the provider’s Remittance Advice or ERA; the Medicare Summary Notice is the beneficiary’s notice. An Original Medicare first-level redetermination generally must be requested within 120 days after receipt of the initial determination. Other appeal levels and payers have different rules. See source 3.
• Action: Create a spreadsheet of open claims, noting CPT codes (e.g., 98940, 97140), submission dates, and statuses.

3. Verify Insurance and Authorizations

Accurate insurance records prevent denials and ensure compliance.

• Chiropractors: Confirm the patient’s coverage and medical necessity. Original Medicare has no fixed annual visit cap for covered chiropractic care, but does not cover maintenance manipulation. Identify any payer-specific rules separately rather than treating a plan limit as an Original Medicare rule. See sources 1 and 4.
• Physical Therapists: For 2025, the KX modifier threshold is $2,410 for PT and SLP combined, and separately for OT. The $3,000 threshold concerns targeted medical review, not automatic prior authorization; not every claim above that amount is reviewed. Check Medicare Advantage and other payer authorization requirements separately. See sources 5 and 6.
• Action: Cross-check patient records for updated insurance details and authorization numbers.

4. Complete MIPS Reporting Preparation

For clinicians subject to MIPS, the 2025 final score affects 2027 Medicare Part B professional-service payments. An adjustment may be positive, neutral, or negative; do not assume a guaranteed increase. See source 7.

• Eligibility: Mandatory individual participation generally requires exceeding all three low-volume criteria: more than $90,000 in Part B covered professional-service allowed charges, more than 200 Part B patients, and more than 200 covered professional services, subject to the determination-period rules and other exclusions. Group and opt-in rules may differ. Check the clinician’s QPP participation status. See source 8.
• Data Collection: Select measures appropriate to the reporting pathway and available measure set. For 2025, applicable eCQM, MIPS CQM, Medicare Part B claims, and QCDR measures use a 75% data-completeness threshold. Apply each measure’s denominator, exclusions, and other specifications; do not equate completeness with the percentage achieving the desired outcome. See source 9.
• Action: Prepare data using the applicable submission method. The standard 2025 submission window was January 2–March 31, 2026; Medicare Part B claims measures are submitted during the performance year. Verify any applicable exceptions and intermediary deadlines. See source 10.

5. Update Patient Accounts

Clean patient accounts reduce disputes and ensure compliance with billing transparency.

• Review Balances: Identify outstanding copays or deductibles, sending reminders for balances over 30 days.
• Verify Coverage: Check 2026 insurance details for returning patients to avoid claim rejections.
• Action: Send clear statements, e.g., “Your 12/01/25 visit (98940) cost $50; you owe $15, due 12/31/25.”

6. Conduct a Compliance Self-Audit

A self-audit can identify errors before an external review; it does not guarantee that a practice will avoid an audit.

• Check Key Areas: Review CPT codes, modifiers (e.g., AT), ICD-10 matches, and documentation for 98940 or 97110.
• Sample Claims: Consider a risk-based sample, such as 5–10% of 2025 claims, for missing documentation or coding errors. This is an internal planning example, not a CMS-mandated sample size.
• Action: Document findings and use the appropriate correction or appeal process. Add an omitted AT modifier only when the actual service and supporting record establish active/corrective treatment. Never use AT for maintenance care or alter records to imply unsupported services. See source 1.

7. Prepare for 2026 Compliance

Use year-end to plan for upcoming Medicare changes.

• Review Updates: Review finalized 2026 CMS policies and applicable code-set updates, distinguishing final requirements from proposals.
• Update Templates: Revise SOAP notes, P.A.R.T. criteria, or PT time logs for 2026 rules.
• Action: Schedule staff training for January 2026 to cover new compliance requirements.

Year-End Compliance Checklist

Use this checklist as a year-end review framework, not a guarantee of compliance or a substitute for claim-specific deadlines:

1. Audit Documentation: Verify P.A.R.T. criteria for chiropractors and time logs for PTs in 10–20 claims.
2. Reconcile Claims: Track the one-calendar-year Original Medicare filing limit and the separate 120-day first-level redetermination period, where applicable.
3. Check Insurance: Confirm coverage and any payer-specific authorization requirements; distinguish them from therapy review thresholds.
4. Prepare MIPS Data: Check eligibility, reporting method, and the applicable 2025 submission timetable.
5. Update Patient Accounts: Send statements for outstanding balances and verify 2026 coverage.
6. Conduct Self-Audit: Review 5–10% of claims for coding and documentation errors.
7. Plan for 2026: Update templates and schedule staff training for new rules.
8. Use Technology: Leverage software to track claims and documentation. Tools like Billing Dynamix can support the workflow; verify that the selected system meets your practice’s reporting needs.

Common Compliance Mistakes to Avoid

These errors can trigger audits or penalties:

• Incomplete Documentation: Incomplete clinical findings or insufficient therapy-time documentation can undermine support for the billed service.
• Missing AT Modifier: Omitting AT from a supported active-treatment claim can result in denial; adding AT does not by itself establish medical necessity.
• Late Claims: Claims received after the applicable filing limit are generally denied unless a recognized exception applies.
• Incorrect Coding: Using a code inconsistent with the treated spinal regions or reporting unsupported therapy units can cause inaccurate claims.
• Skipping MIPS: Clinicians required to participate may face a negative payment adjustment for failing to meet reporting requirements; verify eligibility and any exceptions.

Benefits of Year-End Compliance

A compliant year-end process offers these advantages:

• Higher Revenue: Following up on eligible unpaid claims may recover revenue; the amount depends on the practice’s actual claims and payer decisions.
• Lower Audit Risk: Complete documentation supports a response to medical review but does not prevent selection for an audit.
• Improved Cash Flow: Timely claims and collections boost funds.
• Patient Trust: Clear billing enhances satisfaction.
• Strong 2026 Start: Compliance sets up efficient operations.

Tools to Support Compliance

Practice management software can automate claim tracking, documentation, and MIPS data collection. Systems like Billing Dynamix streamline these tasks, but any reliable tool can help. The key is to use technology to ensure accuracy and compliance.

Conclusion

Completing a year-end compliance checklist in 2025 is critical for chiropractic and physical therapy practices to avoid penalties and maximize revenue. By auditing documentation, reconciling claims, and preparing for MIPS, you can close out the year confidently. Use this checklist with payer guidance and appropriate professional review to support your practice’s compliance work.

Sources

1. CMS: Medicare Documentation Job Aid for Chiropractic Doctors.
2. CMS: Maximum Period for Submission of Medicare Claims.
3. CMS: First Level of Appeal—Redetermination.
4. CMS: Misinformation on Chiropractic Services.
5. CMS: Therapy Services—KX and Targeted Medical Review.
6. CMS: 2025 KX Modifier Threshold Amounts.
7. CMS QPP: Final Score and Payment.
8. CMS QPP: Eligibility Determination.
9. CMS: QPP Policy Comparison—2025 Data Completeness (page 7).
10. CMS QPP: Collect and Submit Data.