Changes in OON Billing and Guidance on the HHS Terms and Conditions
April 17, 2020
by Sean Weiss, Partner & VP of Compliance
Amanda Waesch, ESQ of Brenna Manna Diamond,LLC (BMD), produced two very good blog posts yesterday on OON Billing and the HHS Terms and Conditions that are both quick but very good reads to ensure you are remaining up to date with everything. Two big items Amanda addressed are the following:
- “One of the big issues will be balance billing OON patients under the T&Cs. The issue with the small tweak yesterday is that a broad interpretation of a POSSIBLE COVID patient means essentially every patient that presents is COVID-related. So then all OON patients should be billed as in-network under the T&Cs under the public health emergency as every patient is a possible COVID patient.”
- “Issues with collecting the patient cost-sharing amount from the payor for COVID-related items and services. I’m advising changes to the Patient Financial Responsibility Form and a Billing Policy to show HHS (when they come back to audit!) that the practice was in compliance and understood the T&Cs.”
Below are the links to both of her articles.
Sean M. Weiss is a Partner and serves as VP/Chief Compliance Officer for DoctorsManagement, LLC based in Knoxville, TN. DoctorsManagement, LLC services more than 20,000 clients nation-wide and has been in existence since 1956. Weiss serves as an Investigator and expert witness in Federal and State cases as well as an expert or lead in Administrative Law Judge Hearings. During his 25-year career, Weiss has engaged in more than 200 cases working with law firms and health systems across the country. Weiss serves as a third-party compliance and regulatory officer for more than a dozen health care organizations across the country of varying sizes. For more information on Sean M. Weiss or DoctorsManagement, LLC visit us online at www.doctors-management.com or contact us directly at 800.635.4040. You can also follow Sean on his biweekly Blog on LinkedIn (Sean M. Weiss “The Compliance Guy”) or at www.thecomplianceguyblog.com
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