Don't charge Medicare “substantially” more than your private payers; 21% is one guideline

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Note:  The following article synopsis was NOT provided by HCPro. It was created by Find-A-Code/innoviHealth.

Article Overview

This article explains a Medicare compliance issue for physician practices: how charges to Medicare compare with charges to other payers and why that comparison matters. It is aimed at practice owners, billers, and coding/compliance staff who manage fee schedules, payer contracts, and charge policies. The discussion covers the legal framework, advisory guidance, multiple fee schedule considerations, managed care implications, and handling of non-insurance patients.

Why This Topic Matters

Understanding how Medicare charge levels relate to other payer rates can help practices evaluate compliance risk when setting fee schedules and negotiating payer contracts. The article is relevant to offices that use multiple pricing structures or have Medicare as a secondary payer.

Article Sections

  1. Medicare charge standard and enforcement perspective

    Introduces the legal framework governing Medicare charges compared with other payers and summarizes the enforcement context discussed by the article.

  2. Interpreting the standard and advisory guidance

    Reviews the ambiguity in the standard and references advisory guidance and professional opinions about how practices assess risk under the law.

  3. Multiple fee schedules and payer contract considerations

    Discusses differing views on whether more than one fee schedule is advisable and the general concerns raised by discounted contract arrangements.

  4. Secondary Medicare and non-insurance patient pricing

    Covers additional practice scenarios involving Medicare as a secondary payer and pricing approaches for patients without insurance.

What You Will Learn

  • The general Medicare charge-comparison issue described in the article
  • Why fee schedule structure can affect compliance risk
  • How the article frames uncertainty in the governing standard
  • What practice scenarios are discussed for managed care, secondary Medicare, and uninsured patients

Who Should Read This

  • Physician practices
  • Orthopaedic offices
  • Medical billers and coders
  • Practice managers
  • Compliance staff

Modifiers Discussed


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