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This webinar will review the federal and state compliance requirements concerning co-payments, deductibles and coinsurance amounts. Specifically, this presentation will review what to charge, when to waive, best practices for collections, and best practices for compliance. You may face compliance risk if you fail to collect copays and deductibles. There are lots of thing that you need to know:
How much should you collect?
Can you discount?
Can copays be waived?
Does waiving copay violate the Anti-Kickback Statute?
Can you offer prompt payment reductions?
Proper collection of copays for both private and government payers can protect form severe violations like civil damages and forfeiture, civil monetary penalties, imprisonment, criminal fines, and payer exclusions. Nationally Recognized Healthcare attorney Amanda Waesch, Esq., can help you protect your practice. She will walk you through exactly how your practice can avoid copay collection violations and still receive the payments you are due.
Learning Objectives
Understand the definitions of patient cost-sharing amounts: co-payments, deductibles, and coinsurance
Explore compliance concerns regarding routine waivers of patient cost-sharing responsibility under both federal and state law
Discuss best practices for collecting patient cost-sharing portion
Identify best practices to ensure compliance
Know about prompt payment policy, Self-Pay Policy, financial hardship policy and how to draft these documents compliantly
Know why the routine waiving patient cost share is dangerous
Key considerations in waiving patient cost share responsibility
Impact of Medicare & federal healthcare programs versus commercial health plans
Areas Covered in the Session
What to Charge
Deductible vs. Copayment vs. Coinsurance
High Deductible Health Plan
Examination of Accounts Receivable (A/R)
When to Waive
Routine Waivers
Medicare fraud
State law violations
Breach of contract (for in-network providers)
Fraud and Abuse Laws
The Anti-Kickback Statute
Anti-Kickback Examples
Anti-Kickback Statute Penalties
Civil Monetary Penalties Law (CMPL)
Criminal Penalties
Civil Monetary Penalties Law (42 U.S.C. §1320a-7a)
OIG may impose civil monetary penalties
Civil Monetary Penalties Law
OIG Examples and Warning
How to Collect More
Best Practices for Collecting Copays and Deductibles
Patient Financial Responsibility Form
Payment At the Time of Service
Use of Technology
Policies and Procedures
Patient Credit Balances
Prompt Pay Policy
Self-Pay Policy
Charity Care Policy or Financial Hardship
Bad Debt Policy
Written policy
Collection efforts
Identify when A/R will be written off as bad debt
Reference other policies
Assists in defending “routine” waiver of copayments and deductibles
Amanda Waesch has experience of 18 years and operates a national healthcare practice and is licensed in both Ohio and Florida. She primarily focuses her practice on healthcare, employment law, corporate law, and healthcare litigation and advises all types of employers, in particular healthcare providers, including, hospitals and physicians, on various matters.
She also chairs the firm’s litigation team that is primarily responsible for handling all reimbursement audits and appeals for her firm’s healthcare clients and heads up BMD’s Provider Relations, Audit, Appeals, and Negotiations Unit (PRAAN) which handles all-payer audits, appeals, overpayments and payment extrapolations.
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Course Content
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