Self Pay and Insurance fee schedules

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In all of my research on this, I can't seem to find a definitive answer. Please help and provide a link or citation if possible. We accept Medicare and Medicaid along with most commercial insurances.

1) Is it allowed to have separate fee schedules for self pay patients and insurance patients? I'm not talking about a prompt pay discount for self pay where every service would be discounted the same percentage amount, but rather a totally different fee schedule. Most services on the self pay fee schedule would be lower than the insurance fee schedule, but at varying percentage amounts. Other services would be at the same rate. No services on the self pay fee schedule would be higher than insurance fee schedule. It's possible that some services on the self pay fee schedule may be set lower than the Medicare reimbursement amount.

2) If so, can a prompt pay and/or charity care discount be applied to the self pay fee schedule when appropriate?

3) Can services for self pay patients be offered at a 'package' price (ex: IUC insert and IUC device for a base price for self pay patients regardless of the device type (Mirena, Liletta, Kyleena, etc))? For insurance patients, each service would be billed separately specific to each device.

Thanks!
Kevin
 
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