Potential Concerns for Chiropractors Regarding H.R. 539 – The Chiropractic Medicare Coverage Modernization Act of 2025 

H.R. 539 proposes to expand Medicare (CMS) coverage by recognizing doctors  of chiropractic as physicians for Medicare purposes and allowing  reimbursement for services within a chiropractor’s state-defined scope of  practice. While many in the profession may welcome these changes, principled  chiropractors may view several provisions of the bill with concern.

1. Designating Chiropractors as “Physicians” 

Recognition as physicians is likely to bring chiropractic under regulatory  systems originally developed for medical practice. H.R. 539 will likely require  CMS to establish national standards governing chiropractic evaluation,  documentation, quality reporting, and medical necessity. Unless the chiropractic  profession plays a central role in developing those standards, they will likely be  derived from medical models that were never intended to evaluate chiropractic  care.

Chiropractic and medicine are distinct professions with different educational  models, diagnostic frameworks, clinical objectives, and approaches to patient  care. While both professions serve important roles in healthcare, one should not  simply be evaluated using the standards developed for the other.

The term “physician” will accelerate the assimilation of chiropractic into a  medical framework, diminishing the profession’s separate identity and traditional  principles, weakening healthcare options and outcomes for Medicare  beneficiaries.

2. Medicare Coverage for All Services Within State Scope of Practice 

The bill would allow Medicare reimbursement for services that fall within a  chiropractor’s legal scope of practice under each individual state law. This  creates an incentive for broader scopes of practice and greater dependence on  third-party reimbursement.

Expanded insurance reimbursement leads to increased documentation  requirements, coding demands, compliance obligations, and greater federal  oversight of clinical decision-making. History suggests that every expansion of  Medicare benefits increases administrative requirements.

Additionally, CMS will be forced to determine which services are “reasonable  and necessary”. Eventually Medicare—not state law—begins defining  chiropractic.

History reveals that Medicare has already defined the practice of Chiropractic: • “maintenance care”

• “active treatment”

• “reasonable and necessary services”

• “documentation expectations”

3. No Medicare Opt-Out Provision 

A significant concern is that the legislation does not include an opt-out  mechanism similar to that available to medical doctors and certain other  healthcare providers. Without an opt-out provision, chiropractors must  participate in Medicare, and therefore remain subject to Medicare’s rules and  limitations when caring for patients whom have Medicare benefits. This  perpetuates an unequal standard and limits professional autonomy.

Conclusion 

H.R. 539 represents more than a reimbursement bill; it signals a shift in the  profession’s identity and relationship with government healthcare programs.  While supporters see expanded access, we view the bill as increasing federal  influence and federal costs, encouraging further integration of chiropractic into  the medical model, and failing to address long-standing concerns about  professional autonomy and the right to opt out of Medicare participation.