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Disregarding Excluded Services -Making Sure Your Charges are Compliant

The Rule

You must charge Medicare patients for those statutorily excluded services that are never covered by Medicare when ordered or delivered by a chiropractor. These include x-rays, exams, therapies and extra spinal manipulations. Giving away these services to Medicare patients is viewed as an inducement to obtain federal program monies and can result in fines and penalties of more than $10,000 per item.  You may not give any item or service to a Medicare patient that exceeds a value of $15 with a $75 annual limit per Medicare patient.

Disregarding Excluded Services

Your Compliant Options

You can offer a 5-15% Time-of-Service Discount

Federal guidance dictates that a 5-15% discount on actual fees may be appropriate when the patient pays promptly. You may elect to offer such a discount when statutorily non-covered services are paid at the time of service.

You can join a Discount Medical Plan Organization Network (DMPO) like ChiroHealthUSA

KMC University’s top recommendation is that providers join a DMPO and we prefer ChiroHealthUSA ( Medicare patients can join and enjoy these network-based discounts because they are “under-insured”. This means that they are insured through Medicare for their covered adjustments, but not for other services. Providers can legally discount these services for members of the DMPO and offer lower fees if desired. Patients can then pay these discounted fees for the services, either at the time of service or on a payment plan.

You can implement a Hardship Policy and Fee Schedule

Medicare patients, as with many people, are sometimes financially needy. Since most of the services rendered in a chiropractic office are not covered by Medicare, the financial burden falls to the patient. Providers may implement a hardship policy and fee schedule. One of the most important components of a good Hardship Policy is the clear indication of how you verify that financial hardship. As you consider your hardship policy, it’s essential to strengthen the validity of the policy with details about how you will verify hardship. Whether you are offering a hardship option to a Medicare patient seeking relief for copayment and deductible, or for non-covered services, a strong statement of your willingness to verify should indicate your commitment to fee schedule compliance. The Office of the Inspector General advises, “This hardship exception, however, must not be used routinely; it should be used occasionally to address the special financial needs of a particular patient. Except in such special cases, a good faith effort to collect deductibles and copayments must be made.”

If you choose the hardship policy option, be sure to reach out to a KMCU Specialist for assistance with creating a compliant hardship policy.

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