BC Advantage - 2020 Issue 2
It is My Organization: I Can Do What I Want
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Article Overview
This article explains why waiving patient cost-sharing or offering discounted collection practices can raise compliance concerns for healthcare organizations and medical practices. It summarizes federal government guidance, including Medicare and OIG positions, and discusses related federal laws, state restrictions, and private payer contract issues. The article is aimed at providers, compliance staff, and administrators who need a general overview of the risk areas involved in cost-sharing waivers and discount policies.
Why This Topic Matters
Cost-sharing waivers and discount practices can create exposure under federal and state fraud-and-abuse rules and can also conflict with payer contracts. Understanding the compliance landscape helps organizations reduce legal risk and support defensible billing and collection policies.
Article Sections
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Federal guidance on waivers and discounts
Introduces the general compliance issue and summarizes the roles of Medicare, CMS, and the OIG in addressing patient payment waivers and discount practices.
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OIG concerns and permitted hardship considerations
Reviews the types of practices the OIG has identified as problematic and the broad circumstances under which financial hardship concerns are addressed.
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Federal laws implicated by cost-sharing waivers
Discusses the federal legal frameworks that may be implicated when cost-sharing amounts are waived for government program beneficiaries.
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Special fraud alert and compliance risk areas
Summarizes the OIG’s warning signs and compliance concerns related to advertising, collection practices, and routine waiver approaches.
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Other legal and contractual considerations
Covers additional issues involving Stark law, state restrictions, and private payer contract terms, along with the importance of policies and documentation.
What You Will Learn
- The general compliance concerns associated with patient cost-sharing waivers and cash-pay discounts
- How federal oversight organizations address routine waiver practices
- Which broad federal legal frameworks may be implicated
- Why state law and private payer contracts can also affect waiver policies
- The importance of internal policies, documentation, and staff training
Who Should Read This
- Physicians and medical practice owners
- Healthcare compliance officers
- Billing and revenue cycle staff
- Hospital and health system administrators
- Medical auditors and consultants
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