Discounting Can Cause Compliance Issues for Anesthesia Group

Anesthesiologists know professional courtesy, co-payment waivers and discounts for cash payments could cause compliance issues. You need to know the nuances to three situations; Professional Courtesy, Waiver of Co-pays & Cash Pre-payment versus Insurance, to avoid compliance issues. 

1. Professional courtesy. It is legal to provide courtesy to physicians in the community, other healthcare providers, and their staff, generally speaking. However, it becomes illegal is when courtesy targets physicians or people who are in a position to refer federally-insured patients to the practice. This is a Stark violation. Suggestion: Offer the courtesy discount to all physicians on the medical staff and the CRNAs & AAs that practice at your contracted facilities.

2. Waiving co-pays or accepting “insurance only” as payment. Patient co-pay waivers are generally illegal and certain states have deemed “insurance only” billing as fraud. There is however, one limited exception to the prohibition of co-pay waivers — a waiver based on demonstrated financial hardship. Practices must determine a process in terms of what patients need to provide to qualify for this exemption. Suggestion: Follow the hospitals hardship policy, if the hospital approves the patient discount the same level. You can discount the patients balance after they have received a single statement after insurance has made payment without violating any contacts.

3. Discounts for cash payment. The practice of bypassing insurance is legal, but anesthesiologists need to check whether undercutting their own negotiated rates violates any of their health plan contracts. Suggestion: Only allow cash pre-payment prior to surgery. 

Anesthesia Business Consultants mum over federal investigation involving ‘health care fraud’

Anesthesia Business Consultants spokespeople are mum over an ongoing investigation into allegations of health care fraud a day after federal agents searched the downtown Jackson business.

Agents executed a federal search warrant at the business, officials with the U.S. Department of Health and Human Services Office of Inspector General confirmed Wednesday morning, July 15.

Anesthesia Business Consultants officials would not comment on the investigation Thursday morning, July 16. Media representatives are not allowed in the building, 255 W. Michigan Ave., officials said.

A news release from Anesthesia Business Consultants released about 5:30 p.m. Wednesday said representatives “are cooperating in the collection of the requested information and expect that our full staff in Jackson will resume business as usual.”

“There will be no disruption of service to clients,” the release read.

Federal agents are looking into “allegations of health care fraud, included but not limited to the Medicare program, the Medicaid program and some private insurance companies,” Joseph Napolitano, assistant special agent in charge, said Wednesday.

About 20 agents and 10 forensic specialists imaged computers and seized miscellaneous paper documents. The health care business closed its doors and sent a handful of employees home after the federal agents arrived about 9:30 a.m. Wednesday.

“It’s just an allegation at this point,” he said. “We’ll review the evidence and move on from there.”

Anesthesia Business Consultants employs roughly 300 people in its downtown Jackson offices. The company processes medical billing records before claims are sent to Medicare and Medicaid.

Will Forgrave covers city and county government for the Jackson Citizen Patriot. Contact him at or 517-262-7554. Follow him on Twitter at @WillForgrave.