The question of whether a Doctor of Chiropractic (DC) can write a Letter of Medical Necessity (LOMN) for a patient is an important one that directly impacts coverage and reimbursement. The answer is complex and depends almost entirely on the recipient of the letter, such as a specific insurance company, a government program, or an account administrator. While a DC is a licensed healthcare provider legally authorized to diagnose and treat conditions, the practical acceptance of their documentation varies widely across different financial and regulatory bodies. The DC’s scope of practice, payer policies, and the specific service being requested all influence the outcome.
Defining the Letter of Medical Necessity
A Letter of Medical Necessity is a formal document provided by a licensed healthcare professional that justifies a specific treatment, device, or service. Its primary function is to establish that the expense is directly related to the diagnosis, cure, mitigation, or treatment of a medical condition, rather than general health or cosmetic purposes. This documentation is typically requested when a treatment or item is not automatically covered under a standard policy or when seeking reimbursement from tax-advantaged accounts like a Health Savings Account (HSA) or Flexible Spending Account (FSA).
To be effective, the LOMN must clearly link the patient’s specific diagnosis, often represented by an ICD-10 code, to the proposed course of action. The letter needs to detail why the recommended treatment is the appropriate standard of care for the condition and what the expected clinical outcome is. It must also include the full name and credentials of the provider, their signature, and the recommended duration of the treatment plan.
Chiropractor Status and Scope of Authority
Doctors of Chiropractic are recognized as licensed healthcare providers in all 50 states, authorized to diagnose and manage neuromusculoskeletal conditions. Their professional licensure grants them the legal ability to write formal documentation, including an LOMN, recommending care within their scope of practice. This scope generally includes manual manipulation, physical therapy modalities, and nutritional or lifestyle counseling related to the patient’s condition.
At the federal level, the Social Security Act defines a Doctor of Chiropractic as a “physician” under Section 1861(r)(5) for limited purposes. This legal status allows DCs to bill Medicare directly, but only for one specific service: manual manipulation of the spine to correct a subluxation. This narrow definition is a key distinction that affects the acceptance of an LOMN, as their “physician” designation does not extend to all services or all payers.
The ability of a DC to create the document is separate from the recipient’s willingness to accept it for coverage. A DC can legally recommend and document the medical necessity of care, but that documentation must still align with the recipient’s individual rules. The legal authority to diagnose and recommend treatment remains, but the financial authority to compel payment rests with the payer’s policy.
Payer Policies and Coverage Acceptance
The actual success of a chiropractor-written LOMN depends almost entirely on the party receiving the documentation, as their internal policies dictate acceptance. For federal programs like Medicare, the limited definition of a DC as a physician severely restricts the utility of the LOMN. A DC can use documentation to justify the medical necessity of covered spinal manipulation, but they cannot typically authorize Durable Medical Equipment (DME) or non-manipulative services that require an LOMN, such as certain diagnostic tests or specific medical supplies.
Private health insurance policies vary widely. Some carriers accept an LOMN from a DC for services directly related to a musculoskeletal condition, such as conservative care or physical therapy. However, many private plans require the LOMN for non-manipulative services to be signed by a primary care physician or a specialist with an MD or DO degree. This requirement is often an internal utilization management rule designed to ensure the treatment falls within specific clinical guidelines.
When seeking reimbursement from a tax-advantaged account, such as an FSA or HSA, the Internal Revenue Service (IRS) guidelines are generally more accommodating. The IRS requires an LOMN for expenses that are not inherently medical, like exercise equipment or certain supplements, to verify they are for the treatment of a specific condition. For these purposes, an LOMN written by a DC for an expense within their scope, such as massage therapy to treat a diagnosed back condition, is often accepted by the account administrator. The crucial factor is that the treatment must be a qualified medical expense under IRS rules.
Ensuring Successful Documentation
To maximize the likelihood of a chiropractor-written LOMN being accepted, both the provider and the patient must ensure the documentation is highly detailed and evidence-based. The letter should focus the necessity strictly within the DC’s recognized scope, primarily on neuromusculoskeletal or spinal conditions. Specific details, including the patient’s functional limitations, objective measures of improvement, and precise treatment parameters, should be included to support the claim of medical necessity.
The LOMN should clearly state which prior treatments, such as over-the-counter medication or physical therapy, have failed to resolve the patient’s condition. This establishes that the current, specific recommendation is required to prevent further decline or the need for more invasive procedures. If the payer’s policy is known to be restrictive or ambiguous, seeking a co-signature from the patient’s primary care physician can significantly increase the chances of acceptance. A co-signed letter from an MD or DO provides a recognized layer of medical oversight that satisfies the internal rules of many insurance carriers, bridging the gap between the DC’s legal authority and the payer’s coverage requirements.