Time-of-Service (TOS) discounts are a common occurrence in chiropractic. What is often assumed is that if insurance isn't involved, there are no rules that apply.
Unfortunately, this is a myth that can become costly to practices and damage provider/patient relationships. So read on to learn the facts about TOS discounting and how you can best protect your practice and your patients. Know that illegally or improperly offering TOS discounts can (and do) trigger costly inducement violations that can be crippling to any practice. Knowledge and compliance are two of the best tools to have in order to maintain a practice.
What You Need to Know about TOS Discounts:
First, there are actually rules for offering TOS discounts and these rules, including whether it is even allowed or not, are defined by each state. The first step for any practice considering TOS discounts should be to call their local state Association or Society and ask:
1. Is Time-of-Service Discounting allowed in this state?
2. What other guideline are we required to follow if we should decide to offer TOS discounts?
Most states that do allow TOS discounting do further clarify other steps that must be taken by practices in order to best protect the patient and the practice.
Additionally, it is important to know that the OIG (Office of Inspector General) issued an advisory indicating that chiropractic TOS discounts should not exceed 8-15% AND that discount must be directly tied to the "book keeping savings" that is allowed the practice by not having to submit claims, do follow-up, etc. This must be clearly defined within your Financial Policy so as to eliminate confusion and misunderstanding.
Another must-know for TOS discounting is that there is a reason they are called "Time-of-Service". For eligible patients, practices are able to offer these discounts because it is being paid at the time-of-service and no claims submission, billing or waiting for payment applies. This means, for your eligible patients, if they say "bill me" or "I'll bring a check in next week", they are not eligible for the TOS discount.
When TOS is permitted in a state, keep in mind that your TOS fees are not a "fee schedule" but are actually a "bookkeeping savings" discount from your standard fees. This is why the percentage of discount must be defined and within OIG guidelines. The reason you are able to offer a TOS discount is because of the savings the practice is achieving by not having claims to file to carriers and waiting for processing and payment. This is also why, when they're applicable, TOS discounts are only allowed when payment is being collected at the time of service. Again, invoicing patients this discounted amount is not permitted — it must be collected as services are rendered.
With all of that said, if TOS discounting is not allowed in your state or even if it is but you'd like to explore another possibility, you may very well find that utilizing a DMPO (Discount Medical Plan Organization) suits your practice wonderfully. If asked, most consultants would be encouraging you in this direction so as to minimize practice liability and maximize practice protection.
The specific DMPO option that I'm discussing is CHUSA, otherwise known as ChiroHealthUSA. This is an organization that aids practices in ensuring compliance with fees; thus, also ensuring compliance with local and OIG guidelines. A DMPO is not an insurance company but the program establishes practice fees in a "contract", such as the contracts that insurance carriers have defining their own applicable fees, benefits and limitations that would be applicable for eligible patients under those carrier policies. Practices that utilize a DMPO have the comfort of knowing that they are fully compliant, protected and properly managing discounted services.
Of course, additional benefits to the practice include:
To learn more about how this DMPO program works and the additional benefits available to practices and to patients, visit this link: CHUSA and sign up for a free and informative webinar.
Additional support and questions can be directed to ChiroCode.
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