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JENNIFER KIRSCHENBAUM, ESQ.HEALTHCARE NEWSLETTER    

You are receiving this email as a member of Kirschenbaum & Kirschenbaum, P.C.’s healthcare listserv. 

This email is for education and discussion purposes only and does not constitute legal advice. 

To access prior healthcare email newsletters or articles click here.   

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Balance Billing: Investigations are up,  do you have a policy in place? 

May 20, 2009

 

Talk around the water cooler recently indicates that there is a significant   increase in investigations by both the State and private third party payors  into the payment of co-pays and deductibles.  As such, I'm writing, again,   to stress the need for your practice to develop and implement a standardized system of collecting co-pays.  I know that many physicians claim that their patient population cant afford co-pays or will not tolerate being charged co-pays and I understand that.  I hesitate when I reach my own hand into my wallet at the doctors office, wondering why my insurance doesn't cover my entire visit.  But, at the end of the day, failing to collect co-pays, whether you are a participating provider or a non-participating provider is insurance fraud, and the investigations are increasing in frequency.


So, again, I strongly recommend that you look into implementing a policy whereby you attempt to collect co-pays at the time of any visit and that you have a procedure for making a "good faith" effort to bill patients who do not pay thereafter.  Two exceptions to the rule that you have to collect a co-pay are: (1) treating an indigent patient who legitimately cant afford the co-pay (you're entire patient population is not allowed to fit into this category, it is the exception, not the rule); (2) professional courtesy (if you're partners wife comes in for a check-up, you do not need to charge her the co-pay).




For additional information on this topic, contact Jennifer Kirschenbaum at (516)-747-6700 ext. 308

or at Jennifer@Kirschenbaumesq.com. Click here to access prior healthcare email newsletters or articles.   


COMPLIANCE PROGRAM 

Click here to order required policies and procedures for your practice including your:


(i)Compliance Plan (that provides your policies and procedures that identify and govern how to respond to potential billing and general practice liability);


(ii)Current Patient Privacy Policies (HIPAA, Red Flags Rule and Security Policies have recently changed.  Are you up to date?);


(iii)Employee Manual governing employee acceptable conduct; and 


(iv)Misconduct Pledge that governs licensure matters. 



Questions about why you need the Compliance Program and how the Compliance Program will change your practice?  Contact Jennifer at (516) 747-6700 ext. 308 or at Jennifer@Kirschenbaumesq.com.


Our Compliance Program complies with OIG specifications for individual and small group practices.  All HIPAA and Security policies include modifications pursuant to HITECH Act. www.kirschenbaumesq.com/healthcareorder.htm.


Jennifer Kirschenbaum, Esq.

Kirschenbaum & Kirschenbaum, P.C.

200 Garden City Plaza

Garden City, New York 11530

(516) 747-6700 x. 308(tel)

  1. (516)747-6781 (fax)

www.kirschenbaumesq.com

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