Thanks
If the certificate was for free exams and x-rays what were you wanting to bill to the insurance company?
If the doctor offered something for free, you cant charge the insurance company for the free item.
He also has to be careful that the free offer isnt used as an inducement for self referral which could be a possible violation of the Stark Act. It might be misinterpeted as a possible kickback even though it isnt. It could be the interpretation alone.
Also be careful with unbundling such as taking XXX service which also contains yyyy, then offering yyy for free but billing xxx.