Payments > Patient Billing

Offering cash discounts on self-pay being gamed by patient

(1/3) > >>

trw:
Our company offers a courtesy / cash discount on self pay balances if paid at the time of service.  The discount is offered to reduce billing costs and in consideration of the time value of money.

One of our patients is paying their bill, receiving the discount and apparently billing their insurance themselves and collecting more than they ultimately paid us.  The physicians at the site think this is ok.  Can anyone give me something I can use to support my position that this is not ok?   

Let me extend the question:  is it legal to offer a cash discount on deductible/co-pay/non covered balances to patients with insurance as opposed purely to patients that are solely self pay?

Thanks. 

PMRNC:

 Ok, first of all there is no balance if the patient pays at time of service  ???

Second.. I am ASSUMING you don't participate with the carrier? And also that you are not submitting the claim to the carrier at all?

Third.. IF they are paying cash, are you giving them a receipt for the full fee? You have to be if they are sending it to their carrier!  Yes it's fraud , but it's on your end if it's your superbill/billing statement they are submitting.

Pay_My_Claims:

--- Quote from: trw on August 12, 2009, 09:00:00 PM ---Our company offers a courtesy / cash discount on self pay balances if paid at the time of service.  The discount is offered to reduce billing costs and in consideration of the time value of money.

One of our patients is paying their bill, receiving the discount and apparently billing their insurance themselves and collecting more than they ultimately paid us.  The physicians at the site think this is ok.  Can anyone give me something I can use to support my position that this is not ok?   

Let me extend the question:  is it legal to offer a cash discount on deductible/co-pay/non covered balances to patients with insurance as opposed purely to patients that are solely self pay?

Thanks. 

I"m confused.....

1. if it is self pay then how are they filing insurance???
2. Are you having them pay up front because you are non-par? If so you should be billing non-assigned and having the patient recieve the payment.
3. Is this the copay deductible then yes if you are a participating provider, you have a legal contract that states that you are in network and must collect the patients coinsurance. This looks like a "kick back".




--- End quote ---

trw:
Clarifications:

* Let's say it is a self pay patient and the bill for today's visit is $100.  We would provide a cash / prompt pay discount of 10% if they paid at the time of service. 
*  What if it is an insured patient who owes $100 for their co-pay and non covered services?  Can the same 10% discount be applied as a collection tool to get cash upfront and avoid collection costs?  I am not talking about waiving the co-pay just discounting it for immediate payment.
* We do not participate with the carrier in question and we are not submitting a claim to the carrier.
* It is my understanding that the patient is using claim forms the office is providing to the patient. 
* When I refer to self pay I am referring to self pay balances whether they be from non-insured patients or balances owed from patients with insurance.
* Are we able to discount the co-pay as a means to collect the balance at the time of service eliminating the need to bill the patient and make collection calls?  This is a discount not a waiver of the co-pay.  I read several sources saying the OIG has ok'd discounting as a means to avoid collection costs.
* In an internet search I found a number of hospitals / offices that post their policies on-line.  it seemed a split as some specifically referring to discounts for the uninsured and others just referring to discounts on cash payments. 

Steve Verno CMBS, CEMCS:
Not being a lawyer, but this sounds like your patient is comitting insurance fraud.  I say this because they are sending a claim for more than what the service cost them. 

Discounts should NOT be given to insured patients.  They have contracted copays, deductibles and coinsurance they are contracted to pay.  To give a discount could b a possible violation of the Stark Act, the antikickback statute, and the false claims act. 

Now, here's a scenario your doctors may not like.  The patient belongs to an HMO.  The patient pays at the time of service, gets a discount. They submit the bill for reimbursement.  The HMO files a complaint that their HMO member is paying out of pocket fo healthcare. The regulatory starts to investigate your providers for possible loss of licensure for a possible State Law violation.  They order you to reimburse the patient.  You submit the claim. The HMO denies for timely filing and you are directed that there is no balance billing. YOU lose and the patient wins and gets free healthcare at your expense.  This happened to one of my providers.  The OIG has stated it is permissable to give uninsured patients a discount.
http://www.healthlawyers.org/News/Advisory%20Opinions/Documents/2009/AO0905.pdf

However if you have a patient with insurance, you need a financial plan, as part of your compliance plan to provide guidance on patient payment issues such as uninsured discounts, financial hardship, cost of collecting vs cost of amount to pay and use of a collection agency for delinquent debts.

Navigation

[0] Message Index

[#] Next page