The Physician’s Back Office

Paperwork for chiropractors

A delivery driver with low back pain from lifting at work asks his chiropractor for a workers’ compensation report, a Family and Medical Leave Act (FMLA) form and a note for his employer, and his mother, who is also a patient, asks about a parking placard. Whether the chiropractor may sign each of these depends on the form, and for some of them on the state.

Key points

  • Under the FMLA, a chiropractor counts as a health care provider for manual manipulation of the spine to correct a subluxation shown by X-ray, or where the employer or its health plan accepts a chiropractor’s certification for benefits.
  • The federal CA-20 counts a chiropractor as a physician only for a spinal subluxation shown by X-ray, while some state workers’ compensation forms name chiropractors directly.
  • Many state parking forms name chiropractors, some only for certain conditions or for a short-term placard.
  • A routine work restriction letter says what the patient can do and until when, and does not need the diagnosis.

A note before you read

I am an internist, not a chiropractor. What I can help with is my knowledge of how to complete the paperwork, so this page sticks to what the forms and the rules say, and I name the source for each example. For a chiropractor the first question on many forms is whether you may sign it at all, and the answer depends on the form and sometimes on the state.

FMLA forms

The FMLA regulations count a chiropractor as a health care provider only for treatment consisting of manual manipulation of the spine to correct a subluxation shown to exist by X-ray, and only while authorized to practice in the state and working within the scope of practice state law defines. So you may complete a WH-380-E for that treatment. If the leave is for something else, or there is no X-ray showing the subluxation, that part of the regulation does not cover you, and unless the route below applies, the patient will need a certification from a provider the regulation does cover. Your certification supports the leave, but whether the patient qualifies for FMLA leave is still the employer’s to decide under the rest of the law.

The same section has one more route. A provider also counts if the employer, or its group health plan’s benefits manager, accepts that provider’s certification of a serious health condition to support a claim for benefits. Whether that applies is something the employer or its plan can tell you.

The rule: 29 C.F.R. § 825.125(b)(1) and (b)(4). FMLA paperwork for doctors covers the form itself.

Workers’ compensation reports

Workers’ compensation forms differ from state to state on whether a chiropractor may sign, so I would read the signature line and the instructions first. Some name you directly. Nevada’s D-39 progress report prints “Physician/Chiropractic Physician” on its signature line. New York’s C-4.3, its report at maximum medical improvement or permanent impairment rather than a routine progress report, says a chiropractor filing it certifies that the injury is a condition the chiropractor may lawfully treat, and that where it is not, the chiropractor has advised the patient to see a physician of their choice. Washington’s Activity Prescription Form asks about work capacity, and its instructions separately name chiropractors who are department-approved examiners among the providers qualified to rate permanent impairment.

The federal workers’ compensation program for federal employees is narrower. Its CA-20 attending physician’s report says a chiropractor counts as a physician only if there is a diagnosed spinal subluxation demonstrated by X-ray, and the law behind it, 5 U.S.C. § 8101(2), also limits the services covered to manual manipulation of the spine to correct that subluxation. Wherever you may sign, a status report wants what the worker can do and until when, such as a lifting limit in pounds and how long they can sit or stand, and workers’ compensation reports do ask for the diagnosis. HIPAA allows you to give what workers’ compensation law requires.

Disabled parking placards

Many states name chiropractors among the clinicians who may certify a placard application, and some limit what you may certify. Missouri’s Form 1776 names a chiropractor among its signers, but the signer certifies having physically examined the patient, and the form makes it a misdemeanor to certify a condition whose diagnosis is outside the signer’s license. It also says the clinician who signs it keeps a copy in the patient’s chart. California’s REG 195 lets a chiropractor certify only three of its conditions, a significant limitation in the use of the lower extremities, the loss or loss of use of one or more lower extremities, and the loss or loss of use of both hands. Colorado’s DR 2219 says chiropractors may certify only a physical impairment, and only for a short-term placard, which the form defines as 90 days or less.

So before you sign, read the form’s signature section and its instructions. If your state’s form leaves out chiropractors, or limits you to conditions your patient does not have, the patient will need to ask a clinician who is authorized. If you may sign, match the patient’s documented limits to the conditions printed on the form, and choose the duration in the state’s own categories. Disabled parking placard applications compares the states, and the Missouri and California pages go through those forms.

Disability statements and work notes

An insurer’s disability claim statement may accept a treating provider despite being called an Attending Physician Statement, so I would read its signature section. New York’s DB-450, the health care provider’s statement for state disability benefits, lists a chiropractor among the providers who may certify it. A routine work restriction letter is simpler. It says what the patient can do and until when, such as no lifting over 20 pounds for two weeks, and it does not need the diagnosis.

Where PatientPapers fits

I built PatientPapers to make this paperwork easier to complete. PatientPapers walks you through the forms chiropractors are asked to complete, such as parking placard certifications, FMLA forms, workers’ compensation forms and work restriction letters, so you can fill them out more quickly and more confidently. You set up your information once on each computer you use. Then you answer one question at a time, and nothing goes on the form until you confirm it. Before you sign, it flags some problems, such as family history on an FMLA form. On a parking form, it also checks your credential and will not let you sign where that state’s form rules your profession out. Then you review the completed form, and if everything looks correct, you sign it and you’re done.

Your patients’ information is encrypted on your own device with a passcode only you know, and none of it is sent to us or anyone else. Because we never receive it, there is no business associate agreement to sign with us. We cannot reset your passcode, so setup asks you to save a recovery code, and if you forget the passcode that code lets you set a new one. HIPAA still applies to how your office handles that computer, any copies you export, and the forms you print and sign. If you want to see whether it helps with your own paperwork, try the free trial, and I think you will find it saves you time and makes the forms more intuitive to complete.

Questions the office asks

Can a chiropractor fill out FMLA paperwork?

Only for treatment consisting of manual manipulation of the spine to correct a subluxation shown by X-ray, within the scope of practice your state allows, unless the employer or its health plan accepts a chiropractor’s certification for benefits claims. The rule is 29 C.F.R. § 825.125(b)(1) and (b)(4).

Can a chiropractor sign a disabled parking placard application?

In many states, sometimes only for certain conditions or a short-term placard. Missouri names chiropractors, California limits them to three conditions, and Colorado to a physical impairment for a short-term placard. Read your state’s form and its instructions.

Can my nurse or medical assistant fill in the form for me?

Yes. A provider can add staff such as a nurse or medical assistant, at no extra charge, and each one gets their own passcode. They can fill in the whole form and mark it ready for you, but only the certifying provider can sign it, so I would read what they entered before signing. Everything stays on one computer, so a simple setup is one laptop or tablet kept just for forms that staff and clinicians share. How staff help with forms is the practice’s to arrange and supervise.

Disclosure

PatientPapers is my own product, built through the same company as this site, so please weigh what I say about it accordingly. One license per certifying provider covers every form it completes, with no charge per form. The free trial has no form limit, but forms signed on the trial print with a trial mark, so they are for trying the app, not for handing to a patient. The pricing and the full description are on the PatientPapers site.

See every form PatientPapers completes