Medicare Compliance & Reimbursement

Put policies in place that ensure collection in most scencarios.

With health care costs skyrocketing, providers demanding 20 percent of all charges from rehab patients seems cruel--especially if they've been hit hard by rough economic times.

But the HHS Office of Inspector General and private payers are both on the case of providers who let too many patients off the hook. If it seems a rehab provider is using easygoing policies to bring more patients in the door, it may land in deep trouble. MLR talked to some experts, who offered these tips to keep copayment policies kosher:

• Make a "good faith effort" to collect everything  billed. Also, gather information from patients to see if they're eligible for a "hardship waiver," says attorney Clay Stribling with Brown & Fortunato in Amarillo, TX.

• Have a written policy. Providers can't set a number, such as a percentage of patients for whom they will waive copayments, says attorney Wayne Miller with the Compliance Law Group in Woodland Hills, CA. Instead, providers should "define the circumstances and conditions" under which they'd waive copayments, Miller says. Circumstances could include patients who are medically indigent and can't afford their care, even if they're gainfully employed.

The provider could also put in place discounts for patients who pay cash, Miller says. In a high unemployment area, the standard discount may be different than in a wealthy area.

• Make some effort to verify the financial need information your patients provide. Some providers will perform a credit check on indigent patients, Stribling reports. Others will have patients bring in a bank statement or other documentation. These aren't the only methods you can use, but some external verification is important. 

• Annually audit a random sample of copayment waivers to make sure the patient filled them out properly, Stribling urges. Providers should ensure their staff isn't granting waivers in questionable cases.

• Don't let staff talk out of line. If a patient expresses financial concerns during patient intake, the intake personnel or other staff shouldn't say something like, "All you've got to do is ignore our first three statements, then we'll send you a form and you won't be billed any more," Stribling says.