Medicare Compliance & Reimbursement

Question: Our practice sees several patients who are on limited incomes. Our physician would like to extend the global eriod of surgical procedures in order to provide continued post-surgical care to these patients for free. Can we do this?

Answer: No, unfortunately, your practice cannot arbitrarily extend the global period of a surgical procedure in order to save a patient money. If a patient needs to be seen after the global period ends, you must charge for the services rendered.

Here's why: If you do not charge for those visits beyond the global period to help the financially strapped patient, the doctor runs the risk of noncompliance with a variety of statutes and regulations, including federal false claims and Stark anti-kickback laws, and CMS coding guidelines, not to mention your payer contracts.

Most global periods are designed to cover two or three postoperative office visits. If your physician gives care for free to the patient after the global period ends, which in effect extends the global period, he is telling the payer that the practice will take less payment for the services. If a payer discovers that a practice is reducing charges for some patients, it will demand the same for its patients. If Medicare learns of this, it will review the claim and could ask for a refund.

If the patient needs visits and services beyond the global period and cannot pay the patient portion of the bill, your practice should set up an installment payment plan or consider invoking your financial hardship policy. If the patient is indigent and cannot pay, he needs to prove financial hardship by providing proof of all income, such as an income tax return, to the physician. After reviewing the proof and seeing that the patient truly has a financial hardship you can write off the bill. The copies of the proof supplied, the practice's review of it, and details of the bill and its write-off must be documented in the patient's record.