Reply Summary - non-collection of co-pay
Ted Trower
Description
Collection
Title:
Reply Summary - non-collection of co-pay
Creator:
Ted Trower
Date:
2/24/2003
Text:
My question to the list on Friday was:
What are the precise requirements for documenting that a client is
financially unable to pay their co-pays? Is a simple letter for the client
enough or are we required to obtain additional proof of financial need?
Responses follow
=================================================
>There is a form.....not sure the title.but I have used it in the past it
>just states that the person is unable to pay the deductible..and then you
>can write it off.
---------------------------------------------------------------------------------------------------
>There is a lot of old wives tales regarding non-payment of the
>co-pay, such as if you send three invoices and they don't pay you
>can write it off, which is kind of true and is not true…mostly not
>true
>
>For Medicare...the co-pay is part of the requirements, the 20% co-
>pay is just as important as the Rx, these requirements must be
>meet and as a provider you have signed a contract clearly stating
>your understanding of the rule and your willingness to enforce the
>rule.
>
>If the patient tells you up front they cannot pay the 20%, then
>legally, you cannot provide the services as they have not meet the
>requirements of Medicare. If you have a letter in your file dated
>before the service stating they cannot pay the 20%, you are
>technically in violation of the contract and can be sanctioned by
>Medicare, and you have created documentation to prove you violated
>the rules.
>
>Make arrangements for the patient to pay a little at a time, after
>a while if they do not or cannot make the payments, then you can
>make a determination to write the amount off, but to do this
>before the services are rendered is abuse at a minimum and could
>be interpreted as fraud.
>
>Beware of advice otherwise, read the contract language very
>carefully, as a Medicare provider you do not have the authority to
>waive a co-pay, you do however have the authority as a businessmen
>to write off bad dept,
>
>If you have direct knowledge or documentation before date of
>service that the patient will not pay any of the 20% co-pay and it
>is your intention of writing it off, that is called fraud. The
>old wink-wink-nudge-nudge will not survive an audit…many
>practitioners may tell you that they write it off before hand, I
>assure you they have never been audited, and if they do get
>audited, they will be sanctioned.
>
>Anyway, this is my understanding of the Medicare rules, this
>interpertation has served me well. Give me a reply with your
>phone number if you would like to discuss, I could give you a
>call.
---------------------------------------------------------------------------------------------------
>The Office of Inspector General (OIG) has very specific recommendations
>on how to properly do this. Section 3 subtitle J Routine Waiver of
>Deductibles and Co-Pays states recommended procedures to waive these
>charges. Basically, you have to have a policy where everyone is judged
>objectively. They do not say EXACTLY how to do this, so you have some
>geographical and personal flexibility for your P&P's. We have a form
>that one has to fill out to apply for waiver and we require a copy of a
>tax form showing total income and total dependents. I then made a chart
>with the federal poverty level and # of dependants. If the applicant
>makes less than 150% of the federal poverty level, we will waive the
>co-pay. We do not waive any deductibles. This meets OIG compliance
>(which is currently voluntary, by the way) and everyone is judged
>objectively.
>
>How's that for specific? :-) These are the types of answers I wish I
>could always receive. Hope it helped.
=================================================
This came about after I had an irate client call me demanding to know why I
was billing him for a co-pay when no one else ever had. This included his
physician, therapist, and previous prosthetist. Now maybe this gentleman
just isn't a very good historian, or maybe none of his previous providers
had to make ends meet, or he could be telling the truth. Anyway it's clear
that I have to get this down as a written policy as to precisely how a
wavier of co-pay will be issued. I cannot accept that it would be
acceptable to deny care, sounds like abandonment to me, a classic catch
22. I think if I'm going to stick my head into the noose I'll error on the
side of service.
When it comes to assessing income by tax statements, this would completely
ignore assets. I suspect that this approach might also fail to satisfy
proving financial need.
Thank you for the detailed and informative responses. You have been very
helpful.
Ted A. Trower C.P.O.
A-S-C Orthotics & Prosthetics
Jackson, Michigan, USA
www.amputee.com
What are the precise requirements for documenting that a client is
financially unable to pay their co-pays? Is a simple letter for the client
enough or are we required to obtain additional proof of financial need?
Responses follow
=================================================
>There is a form.....not sure the title.but I have used it in the past it
>just states that the person is unable to pay the deductible..and then you
>can write it off.
---------------------------------------------------------------------------------------------------
>There is a lot of old wives tales regarding non-payment of the
>co-pay, such as if you send three invoices and they don't pay you
>can write it off, which is kind of true and is not true…mostly not
>true
>
>For Medicare...the co-pay is part of the requirements, the 20% co-
>pay is just as important as the Rx, these requirements must be
>meet and as a provider you have signed a contract clearly stating
>your understanding of the rule and your willingness to enforce the
>rule.
>
>If the patient tells you up front they cannot pay the 20%, then
>legally, you cannot provide the services as they have not meet the
>requirements of Medicare. If you have a letter in your file dated
>before the service stating they cannot pay the 20%, you are
>technically in violation of the contract and can be sanctioned by
>Medicare, and you have created documentation to prove you violated
>the rules.
>
>Make arrangements for the patient to pay a little at a time, after
>a while if they do not or cannot make the payments, then you can
>make a determination to write the amount off, but to do this
>before the services are rendered is abuse at a minimum and could
>be interpreted as fraud.
>
>Beware of advice otherwise, read the contract language very
>carefully, as a Medicare provider you do not have the authority to
>waive a co-pay, you do however have the authority as a businessmen
>to write off bad dept,
>
>If you have direct knowledge or documentation before date of
>service that the patient will not pay any of the 20% co-pay and it
>is your intention of writing it off, that is called fraud. The
>old wink-wink-nudge-nudge will not survive an audit…many
>practitioners may tell you that they write it off before hand, I
>assure you they have never been audited, and if they do get
>audited, they will be sanctioned.
>
>Anyway, this is my understanding of the Medicare rules, this
>interpertation has served me well. Give me a reply with your
>phone number if you would like to discuss, I could give you a
>call.
---------------------------------------------------------------------------------------------------
>The Office of Inspector General (OIG) has very specific recommendations
>on how to properly do this. Section 3 subtitle J Routine Waiver of
>Deductibles and Co-Pays states recommended procedures to waive these
>charges. Basically, you have to have a policy where everyone is judged
>objectively. They do not say EXACTLY how to do this, so you have some
>geographical and personal flexibility for your P&P's. We have a form
>that one has to fill out to apply for waiver and we require a copy of a
>tax form showing total income and total dependents. I then made a chart
>with the federal poverty level and # of dependants. If the applicant
>makes less than 150% of the federal poverty level, we will waive the
>co-pay. We do not waive any deductibles. This meets OIG compliance
>(which is currently voluntary, by the way) and everyone is judged
>objectively.
>
>How's that for specific? :-) These are the types of answers I wish I
>could always receive. Hope it helped.
=================================================
This came about after I had an irate client call me demanding to know why I
was billing him for a co-pay when no one else ever had. This included his
physician, therapist, and previous prosthetist. Now maybe this gentleman
just isn't a very good historian, or maybe none of his previous providers
had to make ends meet, or he could be telling the truth. Anyway it's clear
that I have to get this down as a written policy as to precisely how a
wavier of co-pay will be issued. I cannot accept that it would be
acceptable to deny care, sounds like abandonment to me, a classic catch
22. I think if I'm going to stick my head into the noose I'll error on the
side of service.
When it comes to assessing income by tax statements, this would completely
ignore assets. I suspect that this approach might also fail to satisfy
proving financial need.
Thank you for the detailed and informative responses. You have been very
helpful.
Ted A. Trower C.P.O.
A-S-C Orthotics & Prosthetics
Jackson, Michigan, USA
www.amputee.com
Citation
Ted Trower, “Reply Summary - non-collection of co-pay,” Digital Resource Foundation for Orthotics and Prosthetics, accessed November 7, 2024, https://library.drfop.org/items/show/220687.
