Any failure to bill for a service that was provided could be considered a violation of the anti-kickback statute, where you are offering a service without financial expectation (or providing financial incentive to choose you as a provider by adjusting charges in a random fashion). What you want to make sure you do is to have a solid practice policy in place that very clearly defines when you provide a no-charge visit (i.e. surgical global days), what types of financial aid policies you have that would consider (such as a 25% discount for self-pay patients paying by cash on the DOS), and then you have to apply this policy consistently across all lines of business for all patients. The contracts you sign to participate with insurance companies clearly note that you are expected to bill for services you render to their insured, collect copayment, bill correct claims, adjust as they are adjudicated and bill patients when the payer indicates you are to do so. Anything outside that, done randomly, seemingly haphazardly, can land your practice in hot water.
