Cardiology Coding Alert

Recoup Reimbursement From Patients with Medicare Waiver

Unless youre diligent about seeing that your practices Medicare patients sign a waiver of liability statement, you are forfeiting your ability to collect for non-covered services and procedures, such as screening stress tests and pre-op EKGs.

For example, Medicare sends the practice an EOB (explanation of benefits) denying the non-covered charge as well as one to the patient stating that the physician may not bill the patient for these charges. (The Omnibus Budget Reconciliation Act of 1988 limits the amount Medicare patients are liable for services and procedures that are denied as not reasonable and necessary.)

Without a waiver of liability on file, youve just lost your right to collect for those charges, says Sheila Sylvan, principal of IMPACT Medical Consulting in Atlanta, GA. You must have this statement signed in advance of the procedure or service or you cant bill the patient for the non-covered services, she adds.

Because a high percentage of cardiology patients are Medicare beneficiaries, writing off even occasional denials will eventually add up. In addition, auditors may ask to see waiver statements in a prepayment audit.

Here are six tips to help you stop revenue leaks and remain in compliance with Medicare Law (see sample form on page 7):

1. Cite the regulation.
Along with your name and address, and the patients name and Medicare number, make sure the statement clearly, yet briefly, outlines the reason for the waiver.

2. Use first person.
Include a paragraph indicating that the patient understands he or she is responsible for full payment.

2. Explain what is likely to be denied.
Use blanks in which the physician can briefly list each service or procedure, the date, the charge, and the reason why Medicare may deny payment. You can list multiple procedures and dates of service on one waiver statement.

3. Notify patient in advance.
Make sure the patient signs the waiver before each service or procedure is rendered. A blanket waiver is not acceptable. Give a copy of the agreement to the patient and keep one in their chart.

The patient must sign in advance of the procedure, indicating that they understand they will be responsible for payment, explains Connie Cofer, CPS, Cardiovascular Group in Lawrenceville, GA. You cant have them sign it after the test, nor can you have them sign a blank or a general statement for future situations.

4. Bill correctly.
Even though Medicare will not reimburse for the procedure or service, you still must bill your carrier for it. Use the modifier GA, which tells Medicare they are to note on the EOB that the patient is responsible for payment.

5. Watch for routine procedures.
For example, unless the patient specifically signs a waiver for a B12 shot, hepatitis test, liver test, nutritionist [...]
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