Payments > Patient Billing

Offering cash discounts on self-pay being gamed by patient

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PMRNC:

--- Quote ---* 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.
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That's fine as long as your non-par and the statement/receipt you give the patient reflects this discount.


--- Quote ---*  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.
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No. If it's "A" patient in a financial hardship situation, refer to the office policy/financial policy and follow protocol. If your office policy allows for hardship arrangements, document the file, and have the patient complete a financial hardship agreement. ROUTINELY waiving OOP is illegal/Fraud



--- Quote ---* We do not participate with the carrier in question and we are not submitting a claim to the carrier.
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Right but if your office is providing the patient with a "false" statement there's a problem on your end.




--- Quote ---* It is my understanding that the patient is using claim forms the office is providing to the patient.
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That's vague.. do you mean a blank claim form?  I think it's really important that you find out EXACTLY what the office was giving the patient before going any further with this.


--- Quote ---* 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.
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Right but you said "self pay balances if paid at the time of service"  There is a difference. If you are offering a patient a discount as an incentive to pay AT the time of service then it would never be a balance because they wouldn't owe any money unless you are giving them the discount even if they don't pay at the time of service.. what's point?  Again, though .. IF the patient has insurance and you are discounting, the insurance carrier must be billed the same fee. You can't bill the insurance company $100, collect $80 from the patient and turn around and give them a statement for $100. Likewise, if you bill the insurance company (you have to if your participating) you would have to bill them the same discounted fee.



--- Quote ---* 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.
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No you must have read it wrong, you cannot routinely waive copayments, coinsurance or any out of pocket expenses. you must make an attempt to collect.   If the patient has a carrier that you do NOT participate with they would still be in violation of the cost-sharing portion of their policy. Now if you want to give them a discount that's fine but you must bill the insurance company the same rate (discounted) OR show the discount on it's own line of the claim.


--- Quote ---* 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.
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Never use the old "Everyone else is doing it.."    The law is the law.  It sounds like the office does NOT have an office and financial policy and that's a problem. I hate to ask this but do they have a compliance plan.. if you plan to report this what's your protocol to do so? Hopefully there is a compliance plan at the very least in which case you might want to grab a hold of real quick. 

Steve Verno CMBS, CEMCS:
I was doing some research on another guidebook I am writing. I found the following under Texas Law:

Sec. 1204.055.  CONTRACTUAL RESPONSIBILITY FOR DEDUCTIBLES AND COPAYMENTS.  (a)  The payment of benefits under an assignment does not relieve a covered person of a contractual obligation to pay a deductible or copayment.

(b)  A physician or other health care provider may not waive a deductible or copayment by the acceptance of an assignment.

and

Any advertisement, solicitation, or marketing material of a discount health care program may not use the term "health plan," "coverage," "copay," "copayments," "deductible," "preexisting conditions," "guaranteed issue," "premium," "PPO," or "preferred provider organization," or another similar term, in a manner that could reasonably mislead an individual into believing that the discount health care program is health insurance or provides similar coverage.

Qualls14:
At our office we have one particular insurance company that we know does not pay for routine office visits.  Thus, we discount the visit to our spp fee of $60 when we bill the insurance - thus the patient will not be responsible for more than $60.  It is my understanding that as long as you are billing the same amount to insurance as you would provide a patient statement for (whether it is the full $60 or discounted by insurance) that it is legal.
However, I also thought it was legal to write off old account balances that have not been paid as a means to eliminate collection costs for the practice.
Anyone that has any feedback on this please . . . fill us in.
Thanks!

Qualls14:
Also . .  what do you do in the scenario where a patient realizes that they have an extremely high deductible and it would be cheaper to pay the self pay patient rate, rather than to bill their insurance.  Can you allow them to choose to pay self pay and NOT file the insurance? 
My original thought would be no you can't do this, however what do you do for the patients that present and lie stating that they do not have any insurance - just so they can get the cheaper rate?
Anyone got any ideas? ???

PMRNC:

--- Quote ---At our office we have one particular insurance company that we know does not pay for routine office visits.  Thus, we discount the visit to our spp fee of $60 when we bill the insurance - thus the patient will not be responsible for more than $60.  It is my understanding that as long as you are billing the same amount to insurance as you would provide a patient statement for (whether it is the full $60 or discounted by insurance) that it is legal.
--- End quote ---

That would be ok, because the carrier does not pay for routine office visits, so there is no '' cost sharing obligation"


--- Quote ---However, I also thought it was legal to write off old account balances that have not been paid as a means to eliminate collection costs for the practice.
--- End quote ---

It is legal as long as the office has a policy in place to "attempt" collections. This should be in the office policies and procedures, a time frame in which to write off "bad debt" and when to pursue additional collection methods. That's why it's always a good idea that the biller or billing company have and read/understand the practice policies and procedures.
 

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