Paid-in-full discounts?

acerway

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Hi all,

Our doctors are considering implementing a policy that would allow us to give a 20% discount to any patient who pays off their balance in full. We wouldn't advertise the discount, and it would be available to anyone who asks for it, regardless of the balance amount, which insurance package they have, or if they are self-pay.

I've been looking into the legality of this, and I'm wondering if this policy would violate anti-kickback laws, inducement, contracts or anything else. Would you have to prove financial hardship to give someone a discount like this? I'm going to keep researching the OIG, but do any of you experts have advice for this rookie?

Thanks!
 

mitchellde

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This is from Med Focus:
Another form of Professional Courtesy is a percentage discount of the patient’s portion of financial responsibility. There are several considerations to be aware of in this case:



Medicare and other government-funded programs prohibit discounts for patients who are beneficiaries of these programs.
For private insurers, the percentage discount must apply to the entire bill, not just the patient’s portion, and fixed co-payments may not be discounted by the percentage.
To avoid fraud, the insurance company must be informed in writing that the claim represents a discounted bill.
Many private insurance plans and some federal plans include language in the payer-physician contract that allows the plan to pay the lowest charge the physician charges to anyone. Therefore, routine discounts may lead to a reduction in the allowable reimbursement schedule by the plan for all patients.

You can google "physician professional courtesy discount"s and find a ton of information
 

Donna T

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I agree with Debra...you can find a lot of really good information using google. In our office we offer a 30% discount to self pay patients only and it is offered if they pay their bill in full at the time of service. We are a hospital owned physician practice and this is their policy. Good luck with your docs!
 

dclark7

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Everything Debra said is true. In addition offering discounts to insured patients for deductibles. copays or coinsurance could be considered a breach of contract so you would want to check each of your insurance contracts.
 

RebeccaWoodward*

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Hi all,

Our doctors are considering implementing a policy that would allow us to give a 20% discount to any patient who pays off their balance in full. We wouldn't advertise the discount, and it would be available to anyone who asks for it, regardless of the balance amount, which insurance package they have, or if they are self-pay.

I've been looking into the legality of this, and I'm wondering if this policy would violate anti-kickback laws, inducement, contracts or anything else. Would you have to prove financial hardship to give someone a discount like this? I'm going to keep researching the OIG, but do any of you experts have advice for this rookie?

Thanks!
Read:

Why Is it Illegal for ``Charged-Based'' Providers, Practitioners and
Suppliers to Routinely Waive Medicare Copayment and Deductibles?

http://oig.hhs.gov/fraud/docs/alertsandbulletins/121994.html
 

acerway

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Thank you all! You've been very helpful!

This was a good article from the AMA:
http://www.ama-assn.org/ama/pub/physician-resources/legal-topics/regulatory-compliance-topics/health-care-fraud-abuse/professional-courtesy-in-context-health-care.page

So, to put it very simply, it looks like offering the discount as I originally stated it is wrong.

But, we could discount a portion of a patient's balance after reasonable collection efforts have been made, or if they can show a genuine financial need. Thus, it would have to be an older balance.

A rare waiver of a copay or deductible would be OK as long as the intent was to help someone in need, not for inducement.

And I should look into our contracts to be sure there are no further restrictions from our individual payors.

Does that sound right?

Thanks again!
 

LisaHoman

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I work at a large medical collection agency as the compliance officer. We as a rule, discourage our clients from discounting after the account has been assigned for collection. We suggest to our clients that they have a written policy in place, notifying the patients, that the group/doctor may provide (on a case-by-case review) financial assistance to keep the patients account in good standing. After collection agency assignment and reporting to credit bureau, it would be strongly discouraged.
 

CatchTheWind

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My understanding is that as long as the patient has filled out a "Financial Hardship" form and you have accepted that his claim for hardship is valid, then it is okay to write off the balances. Of course, you can't do this indiscriminately; it does have to be a valid hardship.
 

seanny

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We only offer a discount to self-pay, same-day payments to patients carrying a zero balance. I think trying to include the insured is risky.
 
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