AI for Chiropractors in 2026: SOAP Notes, the AT Modifier and Recall

AI can draft SOAP notes, answer calls and restart recall. Medicare's PART, AT modifier and maintenance rules still decide what your note has to show.

The Merlin team9 min read

AI can now draft a chiropractor's SOAP note from the visit conversation, pick up new-patient calls and run reactivation campaigns. It can't decide whether a visit is active care or maintenance, and it can't make a carried-forward note satisfy Medicare. Any tool touching patient data needs a signed business associate agreement first.

The pile-up usually starts after the adjustment: a follow-up note that has to differ from last week's, a patient on visit nine of a plan who has stopped improving, a list of people who dropped off in March. Private practice adds marketing, hiring and recordkeeping on top. The Medicare note comes first below, because that is where a fast tool can cost you the most.

Why a carried-forward SOAP note is the main risk

Speed creates the risk: Medicare wants each chiropractic visit to show what changed, and the fastest AI workflows start from the last note. CMS's compliance tips put the chiropractic improper payment rate at 33.6% for the 2024 reporting period, about $178.3 million, and attribute 95.5% of that to insufficient documentation.

ChiroTouch shows how the convenience works. Its follow-up workflow for Rheo, the AI assistant in that EHR, copies the prior note exactly and updates only the existing macros from what you say in the room. Any line you don't mention stays as it was, so a stale goal or an old exam finding survives until you read it. ChiroTouch says providers still review and finalize notes, and Palmetto GBA's coverage policy says changes in examination, status and progression must be recorded at each visit.

What Medicare looks for, and where a scribe can slip

Medicare detail

What the record needs

Where AI can slip

PART on the first visit

PART stands for pain or tenderness, asymmetry or misalignment, range-of-motion abnormality, and tissue or tone changes. Two of the four are required, one of them asymmetry or misalignment, or range-of-motion abnormality

It hears "tight at L4" and writes pain and tone, which alone miss the required finding

Subsequent visits

Chief complaint, changes since last time, an exam of the involved area, whether treatment is working. A full repeat PART isn't expected

"Feeling better" gets written down with nothing measurable behind it

Spinal regions and CPT

98940 is one or two regions, 98941 three or four, 98942 five. The five regions are cervical, thoracic, lumbar, sacral and pelvic

A region adjusted in silence never reaches the transcript, so the note and the code disagree

Diagnosis

Subluxation first, M99.00 to M99.05, with the precise level treated

Low back pain lands in the assessment instead of the level

Plan of care

Level of care, goals, objective measures, and how today fits the plan, such as which visit this is out of the planned total

A copied plan keeps goals already met, or stops tracking the visit count

Extraspinal work

98943 isn't covered by Medicare

A shoulder or knee adjustment gets blended into the spinal note

Rules differ by Medicare Administrative Contractor, and the policies linked here come from several of them, so read your own contractor's.

Chiropractic AI scribes, from their own documentation

Three products write SOAP notes inside practice software chiropractors already use, so the first question is which system you're on. Their documentation differs on price, consent and what the AI will fill in.

AI scribes inside chiropractic practice software

Tool

What the vendor says it does

Price and limits on its pages

ChiroTouch Rheo

Intake answers into SOAP drafts, English speech into chart notes, history summaries, a Compliance Scan of notes and billing codes. Keeps transcripts and notes, not audio

No added cost for ChiroTouch server and cloud customers. Not yet on mobile phones. One section says the scan flags missing documentation; the FAQ says Rheo won't alert you yet, so ask

ChiroSpring AI

Scribe, note rewrite, summaries of up to 30 treatment notes, and a claims assistant for scrubbing and denials

An add-on switched on in your plan settings, with no price in those help pages. The scribe fills four memo text boxes, not check boxes or drop-downs, so a PART exam recorded in those stays manual

Jane AI Scribe

A microphone in the charting area, and a draft note you review and sign

Five free notes monthly, then $15 per practitioner per month, varying by region. Jane's patient FAQ says practitioners should ask for consent, patient data doesn't train the feature, and recordings aren't part of the legal record

A scribe is a recorder in the adjusting room

Federal law sets a one-party consent minimum, and the Reporters Committee's recording guide counts about 11 states as primarily all-party, so check your state and put consent in your intake paperwork. In an open-bay adjusting room, the microphone may also pick up patients who never agreed to anything. Ask each vendor what happens to that audio.

Active care or maintenance: the call AI can't make

Whether a visit is active care or maintenance is a clinical judgment, and it decides the claim. Medicare treats care as maintenance once further improvement can't reasonably be expected, and maintenance isn't covered. HHS's inspector general has watched this line for years: in a 2015 report on 2013 claims, almost half of $76 million in questionable payments looked like maintenance therapy.

  • The AT modifier. It goes on active or corrective treatment and must not go on maintenance, and its presence alone doesn't show the visit was reasonable and necessary. Never let a template or billing rule apply it by default.
  • ABNs. CMS's Advance Beneficiary Notice, Form CMS-R-131, warns an Original Medicare patient that a denial is expected and shifts the potential cost to them. Contractor guidance pairs it with a GA modifier, or rarely GZ. AI can draft your plain-English explanation of why care is changing. Use CMS's own form for the notice itself.
  • Prolonged care. CGS warns that prolonged or repeated courses are more likely to get medical review. A summary tool can pull a patient's outcome measures across 20 visits, and the conclusion remains yours.

Cash plans: keep your state board's rule beside the draft

AI can turn your fee schedule into a readable care plan agreement, but prepaid plans sit under state rules a general model won't reliably know. Oregon's rule requires a statement that no result is guaranteed and a section labeled "Refund Policy" with a table of the calculations. New Mexico's rule requires prepaid funds to be held in escrow until services are delivered. A cash arrangement with a Medicare patient raises its own questions, so take those to your contractor or a health care lawyer.

Phones, recall and reactivation

Front-desk AI for chiropractors now covers inbound calls and inactive-patient outreach, though patients may not want it on the first call. Both jobs handle patient names and schedules, so each vendor needs its own agreement.

  • Calls. My AI Front Desk lists new-patient intake, rebooking and insurance questions, says it books into ChiroTouch, Genesis, ChiroFusion, Jane and ChiroSpring, routes severe-pain calls to an on-call chiropractor, and advertises a business associate agreement on every plan at $109 a month, with usage charges depending on the plan.
  • Reactivation. SPARK, from ChiroHD, says it finds inactive patients, contacts them by email and text with chiropractic-specific campaigns, and books after hours through a chatbot. Its page shows no price.

Weigh what patients say too. An article on ACA Today cites a OnePoll survey in which 89% would rather reach a real person at a healthcare practice and 29% would hang up on an automated system. The author works for a company selling answering services and the piece doesn't detail the method, so treat those numbers as a warning, not a measurement. A reasonable first use is after hours and overflow.

Recall has a HIPAA wrinkle that works in your favor. Under the Privacy Rule's definition of marketing, describing your own health-related services generally isn't marketing unless someone pays you to send it, so a sponsored supplement offer is a different matter from a note saying you haven't seen someone since March. Keep the message free of clinical detail, because a text preview can sit on a shared phone.

The contract question before patient data moves

A vendor handling patient information on your practice's behalf needs a written contract with you. The Privacy Rule requires satisfactory assurances, documented in writing, before you share protected health information with a business associate, so a "HIPAA compliant" badge on a pricing page isn't enough without the signed document.

General chatbots face the same test. Deleting the patient's name doesn't de-identify a note, since the safe harbor method also removes dates of service, phone numbers and email addresses, among other identifiers. Your email faces it too: Google says Workspace customers without a signed agreement must not use PHI in Workspace services, and that third-party add-ons aren't covered by it.

Where Merlin fits, and where it stays out

Merlin is not a tool for patient information. This Mac app works from the inbox and calendar of whichever Google account you connect, and its privacy policy says the context for a request may go to AI providers, while neither that policy nor its terms mention HIPAA or business associate agreements. Connect only a Google account free of patient mail, keep chart details out of its chat, and don't use it to record a visit. If patient and business mail share one account, don't connect that account.

It also doesn't answer phone calls, run a scheduling system, submit claims, send recall campaigns or do EHR work in ChiroTouch, Jane or anything else. Those jobs belong to the products named earlier. If the books are your headache, see AI for bookkeepers.

What's left is the business side of a practice, the mail no chart ever sees: the landlord, the x-ray service contract, an associate candidate, a seminar registration, your state association.

  • Who you still owe. The People panel's Needs you list picks out direct emails awaiting your answer, from two days old up to 30, and it reads email only. An associate candidate you meant to answer on Tuesday shows up there.
  • Contacts going cold. Gone quiet flags contacts you wrote to three or more times earlier in the past year, once mail has stopped both ways for two months. That suits a vendor or a business contact. It isn't a patient recall list.
  • Replies you approve. Ask in chat to answer the x-ray service company, and a card holds the email until you've edited and confirmed it. Routines, jobs you set Merlin to do on a schedule, can send without a card, so point those at summaries for yourself.
  • Prep and calls. Choosing Prep me on a calendar event sets up a sourced brief before a call with your accountant or a practice broker. The recorder saves audio on every plan, with transcripts on paid ones. Use it only for calls with no patient details and with the other side's consent. Our AI note taker comparison covers other options.

The mail around the adjusting table

Keep your charts where they are. Point Merlin at a Google account that holds the lease, the equipment contracts and the associate search. It lists whose email you haven't answered and holds each reply you ask for until you approve it.

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How to test one AI scribe on real follow-up visits

Test one scribe against Medicare's checklist before you trust it, and start with what your current software already includes.

  1. Ask your EHR vendor first. Find out whether AI is included, what it costs, and whether your agreement covers it. Get the signed agreement before any real visit.
  2. Write the consent step. Add AI recording to intake, decide what a patient who declines gets instead, and check your state's rule.
  3. Say the exam out loud. For two weeks, name the segment, the finding, the change since last visit and each region you adjust, so the transcript has something to work from.
  4. Audit a sample yourself. Check a handful of follow-up notes against CMS's documentation checklist. Look for repeated wording, a region count that disagrees with the CPT code, and AT on patients who have plateaued.
  5. Then touch the phones. Put an AI receptionist on after-hours calls, listen to its recordings, and decide whether it earns the daytime line.

Frequently asked questions

Can AI write chiropractic SOAP notes?

Yes. ChiroTouch Rheo, ChiroSpring AI and Jane AI Scribe all draft SOAP notes from the visit conversation. You still review and sign, and the note has to show what changed at that visit.

Can AI decide whether to use the AT modifier?

No. AT belongs only on active or corrective treatment, which is your clinical judgment based on expected improvement, and the modifier alone doesn't show the visit was necessary.

Do patients have to consent to an AI scribe?

Recording consent depends on the state: federal law requires one party, and about 11 states primarily require all parties. Asking every patient during intake is the simplest policy.

Can I paste a patient's note into a general chatbot?

Not without a signed business associate agreement covering that product. Removing the name doesn't de-identify a note, because dates of service and other identifiers count too.

Can I use Merlin for patient recall or charting?

No. Merlin doesn't do recall campaigns, scheduling systems, billing or EHR work, and its policies don't mention HIPAA, so keep it to a business Google account free of patient mail.

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