Reader Questions:
Consider Medicare Obligations Before Establishing Discounts
Published on Mon Dec 20, 2004
Question: Last month you printed a Reader Question titled "Day-of-Service Discounts Must Be Compliant." This article advised that any type of patient discount is perfectly legal as long as you define the details in your financial policy and apply the discount consistently as defined. But where does Medicare fit into all this? Doesn't CMS require that if you offer discounts to patients, you must offer the same discount to your Medicare carrier?
Pennsylvania Subscriber
Answer: Medicare's policy on discounts is somewhat open to interpretation, but the bottom line is that you don't necessarily have to provide Medicare with the same discount you provide to patients.
One option is to offer a certain discount only to non-Medicare patients - Medicare approves of this approach. For example, you may want to offer a discount only to self-pay patients if they agree to pay their entire balance at the time of service. You would apply this discount only to self-pay patients; therefore you wouldn't have to concern yourself with obligations to Medicare.
If you want to offer a certain discount to all your patients, including Medicare beneficiaries, then your best bet is to consult both your local Medicare carrier and local legal counsel to see how such a discount might affect your Medicare payment arrangements. Medicare carriers may vary as to what discount policies they find acceptable.