Practice Management Alert

You Be the Coder:

Free Postsurgical Care

Test your coding knowledge. Determine how you would code this situation before looking at the box below for the answer.

Question: May a physician give free services to a patient who has had surgery in the past six months by extending the global period? We have a physician who wants to help out patients on limited incomes by giving free care after the global period ends. Can this kind of generosity get them in trouble?

Arizona Subscriber

Answer: Physicians cannot arbitrarily extend a global surgical period (GSP). Many patients need more care after the global period ends. If the patient needs to be seen after the global period ends, you must charge for the services rendered. If the physician does not charge for those visits beyond the global period to help the financially strapped patient, the doctor runs the risk of noncompliance with a variety of statutes and regulations, including federal false claims and Stark anti-kickback laws, and CMS coding guidelines, not to mention his or her carrier contract.
 
Most payments for GSPs are designed to cover two or three postoperative office visits. If the physician gives care for free to the patient after the global period ends, which in effect "extends" the global period, he or she is telling the insurer that the practice will take less payment for the services. If a payer discovers that a practice is reducing charges for some patients, it will demand the same for its patients. If Medicare learns of this, it will review the claim and could ask for a refund.
 
If the patient needs visits and services beyond the global period and cannot pay the patient portion of the bill, the practice should set up an installment payment plan. In this case, the patient would pay an amount per month until the balance due is satisfied. If the patient is indigent and cannot pay, the patient needs to prove financial hardship by providing proof of all income, such as an income tax return, to the physician. After reviewing the proof and seeing that the patient truly has a financial hardship, the physician can write off the bill. The copies of the proof supplied, the physician's review of it, and details of the bill and its write-off must be documented in the patient's record.

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