How to Structure Cash Discounts That Are Legal, Compliant and Easy - - PowerPoint PPT Presentation

“How to Structure Cash Discounts That Are Legal, Compliant and Easy to Explain Even to An Insurance Auditor”

Hosted By Madeleine Silva

On Today’s Call You’ll Learn How To….

• Avoid common pitfalls that get chiropractors

in serious trouble with insurance adjusters and auditors

On Today’s Call You’ll Learn How To….

• Protect yourself and your practice from fraud

investigations and insurance audits

On Today’s Call You’ll Learn How To….

• Train your CA how to confidently answer the

question ‘What do you charge?’ without compromising you or your practice

On Today’s Call You’ll Learn How To….

• Implement clear and concise compliance

procedures into your practice without having to spend hours studying insurance law

Cash vs. Insurance Fees

It’s become common practice for insurance adjusters and fraud investigators to call chiropractic offices and asking your CA, “What do you charge for a visit?”

• Dr. Mark

Before knowing how to re-position his cash discounted fees (or even that is was essential for him to train his CA to do so), Dr. Mark was targeting by an insurance fraud investigator that was a retired police officer. And shortly there after, Dr. Mark was spending his weekend preparing medical records and writing reports to comply with the auditor’s requests.

Insurance Audit Protection Strategy #1

From now on, this is how I want you and your team to answer the question ‘What do you charge?’ ‘Our minimum adjustment fee is XX dollars.’

To Re-Position Your Cash Discounts Follow These 3 Steps:

• 1. Make the charge for your 98940 (spinal

adjustment, 1-2 regions) code the same as your minimal adjustment fee

To Re-Position Your Cash Discounts Follow These 3 Steps:

• 2. Keep the fee the same for the 98940 if you

bill it to insurance or charge it to a cash patient.

To Re-Position Your Cash Discounts Follow These 3 Steps:

• 3. Delete any customized cash fee schedules

from your website, fee schedules or computer systems.

• Dr. Mark cont.

After Dr. Mark shared his story, he said, ‘I’m sure you know what this is like since you work with insurance companies all day long.’

• Dr. Mark cont.

He was shocked when I told him that I have never talked to a fraud investigator in the 22 years that I’ve been billing insurance. You see, I consider it my job to keep my clients

• ut of those sticky situations.

Each Case Classification Have Different Rules

Cash, general insurance, Medicare, personal injury, and workers’ compensation cases all have different laws and guidelines. And there are also different federal and state laws.

• Dr. Mindy
• On of my clients, Dr. Mindy, called me stressed
• ut after attending an insurance compliance

seminar that her coaching group put on (this happens a lot.)

• Dr. Mindy cont.

The seminar leader had told her that she could not offer any incentives – such as free first visit consultation – to any prospective patients anymore.

Insurance Audit Protection Strategy #2

Hire a reputable compliance consultant so that you get your billing and documentations procedures in tip-top shape.

• Dr. Mindy cont.

Once I explained to my client, Dr. Mindy, that the ‘no incentive’ clause only applied to Medicare patients, she began to calm down.

• Dr. Mindy cont.

Having the support of someone knowledgeable about insurance provided her with the perspective to implement what she had learned in just the right way in her practice.

What is Mean to be Compliant

When I first introduce compliance strategies to my clients, many of them ask me: ‘Can’t I just call you when I have questions?’ And the answer is ‘YES, of course, but don’t mistake that for being compliant!’

What it Means to be Compliant

There is no way for a compliance consultant to be able to access your risk without a thorough review of your billing and documentation procedures.

The problem is that what you don’t know, may hurt you. One of my friends from chiropractic school ended up facing 22 years in prison for insurance fraud, by not knowing some of the basics about

• insurance. I read about her arrest in the local

newspaper.

What You Don’t Know

Insurance Audit Protection Strategy #3

Know the Basics! Make it easy to make decisions about billing & marketing, without compromising yourself or your practice.

California Only on Cash Discounts

The California Business & Professional code 657 states:

• (c) Notwithstanding any provision in any health care service

plan contract or insurance contract to the contrary, health care providers are hereby expressly authorized to grant discounts for health or medical care provided to any patient the health care provider has reasonable cause to believe is not eligible for, or is not entitled to, insurance reimbursement, coverage under the Medi-Cal program, or coverage by a health care service plan for the health or medical care provided. Any discounted fee granted pursuant to this section shall not be deemed to be the health care provider's usual, customary, or reasonable fee for any other purposes, including, but not limited to, any health care service plan contract or insurance contract.

General Insurance Discounts

• Routinely waiving of your patients’ out-of-

pocket costs may lead to criminal violations, civil penalties and/or licensure implications for providers.

General Insurance Discounts

The IRS code demands that you do one of two things before you write any patient balances off.

• 1. Substantiate that the patient suffers a

financial hardship;

• 2. Make a collection effort.

General Insurance – Financial Hardship

• A financial hardship agreement needs to be

signed by the patient and provided in the patients file.

General Insurance – Collection Effort

• Collection effort is defined by the IRS as

sending a bill (statement) once each 30 days for a period of 90 days, followed by a demand letter on day 120.

Medicare

‘Under section 1128(a)(5) of the Social Security Act (the Act) enacted as part of Health Insurance Portability and Accountability Act of 1996 (HIPAA), a person who offers or transfers to a Medicare beneficiary any remuneration that the person knows or should know is likely to influence the beneficiary’s selection of a particular provider, practitioner,

• r supplier of Medicare payable items or services may be

liable for civil money penalties of up to $10,000 for each wrongful act. For purposes of section 1128(a)(5) of the Act, the statues defines ‘remuneration’ to include, without limitation, waivers of copayments and deductible amounts (or any part thereof) and transfers of items or services for free or for other than fair market value. ‘

Insurance Audit Protection Strategy #4

Make is FUN & EASY to implement compliance Procedures!

4 Steps To Your Compliance Manual

• 1. Pick a person on your team who will be in

charge of reading all the compliance information & report back to the team.

4 Steps To Your Compliance Manual

• 2. Decide together as a team what additional

information is needed or questions needs to be answered, if any, to implement a change into your compliance procedures.

4 Steps To Your Compliance Manual

• 3. Once you have all the information needed to

make decisions on how and if to change procedures, collaborate together as a team.

4 Steps To Your Compliance Manual

• 4. Delegate the tasks to be implemented to

your team and write them up for your compliance binder.

Apply For A Strategy Session

• The strategy session is for you if you’ve been

taking notes and listened intently to the call today but still aren’t quite sure where to begin to implement these strategies.

Apply For A Strategy Session

• And it’s also for those of you who are feeling

stuck in your practice and want clarity and direction on how to take it to the next level.

Apply For A Strategy Session

• And it’s for those of you that are interested in

finding out more about my coaching style to see if one of my VIP coaching programs would be a good fit for you.

Apply For A Strategy Session

• http://chiropracticallyyours.com/yes/

“How to Package Your Services so Patients Say ‘Yes’ to You” Thursday, November 7, 2013 12-Noon to 1:30pm