by Dr. Ray Foxworth, FICC, MCS-P
- Do you have sound financial and billing policies in writing? Ask for a copy and review them.
- Is there more than one fee schedule? If so, why? And is it legal? In some states, charging more to insurance patients than you do for cash patients is considered a “dual fee schedule” and could be illegal. Ideally, there should be one fee schedule. One of the safest policies is to only offer discounts only when they are part of a written financial policy, which could include contractual or network discounts, mandated fees like those established by Medicare, or when there is a documented financial hardship. If you would like a copy of a simple, one-page financial policy that is rock solid, text BEACON to (601) 273-4085.
- Does the clinic up-code, or down-code based on the type of insurance coverage? Meaning, do they bill a higher level of Evaluation & Management code for PI or Worker’s Compensation cases and a low-level code just because they are cash patients? You want to be sure that the clinic is billing and coding correctly.
- Do you waive deductibles or co-payments? This is clearly a violation of rules and regulations, and most provider agreements, unless a true financial hardship is established by the clinic.
- Do you have a written financial policy that is covered with patients? Many complaints to Boards of Examiners seem to be triggered by a poor financial policy, which is easily eliminated by a written policy.
- Does the clinic have a compliance plan in place to minimize the potential for fraud and abuse and to ensure compliance with all layers of regulations? There are many steps that can be taken today to minimize the potential for audits and mitigate potential fines and penalties.
- Has the practice ever been audited? If so, what was the outcome? Today, it is not a matter of ifyou will be audited, but when. And keep in mind, just because there has been an audit, does not mean someone did something wrong. It could just be that their number came up.
Whether you just started chiropractic school or you will graduate soon, start learning about compliance now. It is never too soon and never too late. I often say compliance is not an event, but a process, and it should be ongoing. Start learning more about billing, coding, and documentation and what a sound financial policy should contain. If you or the practice you are considering joining offers discounts to patients, learn about the role of Discount Medical Plans. They can assist you in helping your patients by offering legal, network-based discounts without putting yourself at risk. Regardless of the decision you make, to start your own business or join an existing practice, remember to give your best to the profession and your patients, and you will not be disappointed. Dr. Ray Foxworth is the founder and President of ChiroHealthUSA. Since it’s inception in 2007, ChiroHealthUSA has donated over $750,000 to help support state associations, COCSA, F4CP and the CCGPP. Dr. Foxworth recently announced the ChiroHealthUSA Foxworth Family Chiropractic Scholarship. Beginning in 2016, one student annually will be awarded a $10,000 scholarship and the students Chiropractic College will receive a donation of $10,000. To learn more and apply, go to www.chusascholar.com.
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Why is the Discount Challenge prize amount $15,024? Because that is the average “per-occurrence” fine for Medicare inducements. That’s not $15,024 per patient, that’s not per provider, that’s PER VISIT. Stinks, doesn’t it? To us, the prize amount is worth the investment if we can help our profession better understand proper discounting.