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.
CMS proposes removal of HCAHPS pain management questions
CMS released its 2017 Medicare Outpatient Prospective Payment System proposed rule, which aims to enhance Medicare patients’ quality of care. In the rule, CMS is proposing to remove the Hospital Consumer Assessment of Healthcare Providers and Systems’ Pain Management dimension, which often determines providers’ reimbursement rates. Here are four takeaways:
1. CMS’ proposal is in response to many healthcare leaders concerns over the pain management assessment’s correlation to opioid prescribing patterns. Often, providers are motivated to prescribe opioids to alleviate patients’ pain, thereby increasing satisfaction scores.
2. The current pain management questions do not ask specially about a type of pain-control method.
3. While CMS does not cite any proven studies that pain management dimension questions are linked to opioid prescribing patterns, the agency is proposing the emission to be cautious about the potential link.
4. Hospitals will continue to publicly report pain management data under the Hospital Inpatient Quality Reporting Program while CMS devises alternative pain management questions
