Home Forums Discussions General Discussion Different Fee Schedules

I have to jump into this discussion. I'll simply identify myself as being an AC billing company. I frequently have to deal with this issue of different fee schedules. A physician is required to have a single retail fee schedule. Period. No fee schedule for cash patients vs. a fee schedule for insured patients. No Medicare fee schedule vs. a commercial insurance fee schedule. This is especially in focus if you a Medicare par provider.

Yes, you can give a discount to an uninsured patient if they're paying cash, BUT it CAN'T be the same discount for every patient regardless of their economic situation. Each cash discount must be negotiated by the patient at the time of payment. Why? Well, under HIPAA and federal laws covering anti-kickback rules, it's considered discriminatory to bill an insured patient and their insurer one fee while charging a lower fee to the cash patient. The solution is to have each cash patient negotiate a different discount in the same way that each insurer negotiates a discount or allowed amount from your retail fee schedule.

I strongly recommend to practices that they establish a uniform financial policy that discusses discounts for cash patients and includes a chart of discounts that start at the current federal poverty level based upon family size, and work up from that.

Why is all of this necessary? Whether you know it or not, each one of you will be audited in the next few years. Varying fee schedules is a punishable offense under the law. The Supreme Court has taken a position on this as well stating that if you accept Medicare or Medicaid, you are a federal contractor and responsible for understanding all aspects of the law that govern your agreements with government entities.

Sadly, practices are all under the microscope and federal auditors are private companies that only get paid when they find your errors. So, if you put in place solid policies that are written, consistent, and enforced internally, you're protecting yourselves. That's of utmost importance these days.