Many Chiropractors are following the trend of shifting to a cash pay treatment plan model for and have done the same for other types of integrated medical services outside of the chiropractic scope. Afterall, why not? Patients want convenience and want to receive treatment somewhere they have an established relationship. Treatment plans have their own set of rules as it relates to amounts allowed to be held, and compliance surrounding those procedures, butthe integration of medical services then triggers general medical and health law regulatory issues and the need for a focus on compliance.
Did you know that as a Medicare provider with an active PTAN number, providers must comply with the Medicare claims submission rule? It doesn’t matter if the entity where you are practicing is not participating, the PTAN tracks with the provider license. It is the responsibility of the provider to verify if a patient is Medicare eligible. Billing a Medicare patient cash for a “covered” service is a violation of the claims submission rule, which providers attest to follow when receiving a PTAN number.
Medicare providers with an active PTAN number must be opted (participating) and must comply with the claim’s submission rules under The Social Security Act (Section 1848(g)(4)).With the increasing trends in cash pay medical business trends, such as IV hydration, HRT, weight loss, and many others, these claim submission rules can get tricky if one of these types of services could end up being “covered.”For the most part, these services are not covered; however, other medical services charged through membership agreements such as office visits and adjustments may check that box as being “covered”.
So the big question is from chiropractors is “What can I do for Medicare patients?”“Can I provide membership services for cash at all to them?” The answer is that rendering “covered” services in exchange for cash is ok, butas long as you follow the proper procedures under an Advanced Beneficiary Notice (“ABN”). Providers can charge a patient who is Medicare eligible cash for “covered” services, as long asthey follow the Medicare Fee-Schedule. Providers can also blend these types of services with other “non-covered” services through concierge agreements. However, providers must be cautious to identify those “covered” and “non-covered” services; this is the challenge and the hurdle to maintain compliance when dabbling in the cash pay medical business arena.
The evolution of chiropractic’s place on the wellness and healthcare continuum has pushed the industry under the same microscope of enforcement that traditional medicine has long since endured. Compliance awareness and regulatory adherence are no longer optional and complicity will dictate success or failure.
