This doc is clearly not above-board. There is no way each patient that comes into his office needs a 98941(some patients only need 98940, some 98942, some 98943)- and if he is manufacturing dx codes in order to uphold his treatment, that is wrong also. One major red flag to insurance companies is a doc that provides the SAME treatment to every patient. That's not to say that many patients can be receiving a 98941- just not all patients the same treatment.

Another thing that makes me uneasy is that you said you had to talk him out of billing an office visit with each manipulation. Even if you use a 25 modifier to get the office visits paid (and it's possible) it's still improper unless he's doing a re-eval for the current problem, a new problem has occurred or patient is being released from care.

As far as dx codes to document- you can add dx codes in box 19 of the hcfa. Most ins co do not require this as long as the diagnoses are noted in the documentation. We've never used more than the four codes on the hcfa form; the main dx are reported on the hcfa and the other related dx are included in the patient's chart, per drs notes.