It is increasingly common for physicians to charge their patients a fee for missed appointments. For example, approximately 31% of MTBC’s clients routinely charge a missed appointment fee. Most of these providers charge approximately $25, while others charge as little as $15 or as much as $100 per missed appointment1.
Until recently, there has been some uncertainty regarding whether a provider is permitted to charge a missed appointment fee to Medicare patients in view of Medicare’s assignment and limiting charge regulations. However, earlier this week, the Center for Medicare and Medicaid Services (“CMS”) explained the following:
CMS’s policy is to allow physicians and suppliers to charge Medicare beneficiaries for missed appointments, provided that they do not discriminate against Medicare beneficiaries but also charge non-Medicare patients for missed appointments.
See, CMS Manual System, Pub. 100-04 Medicare Claims Processing, Transmittal 1279 (October 1, 2007).
The missed appointment charge is not a fee for health care services rendered, but rather, as CMS explains, it is a “charge for missed business opportunity.” This is important because providers (whether participating or non-participating) are only permitted to directly charge Medicare/Medicaid patients specified cost-sharing amounts for health care services. For instance, balance billing is not permitted because, in accepting Medicare/Medicaid’s payment, a provider has agreed not to charge any other amount directly to his or her patient other than the specified cost-sharing amount. If the missed appointment charge was classified as a fee for service, a provider would not be permitted to pass it on directly to the patient; however, since it is classified as reimbursement for missed business opportunities, it may be charged to an offending patient.
If you are considering implementing a missed appointment charge, you should consider the following:
- You can charge a patient for a missed appointment, but this charge is not reimbursable; therefore, do not waste your time submitting a claim to Medicare or Medicaid because it will be denied.
- You cannot charge one fee to Medicaid/Medicare patients, while charging a different fee (or no fee) to self-pay/commercial payer patients. Such unequal treatment violates the Medicare and Medicaid statutes and regulations.
- It is a good practice to have new patients sign and acknowledge your office’s policy regarding missed appointment charges. This will help eliminate any confusion if your patients balk at paying your fee.
- From a business standpoint, it makes sense to build flexibility into your missed appointment charge. For example, many MTBC clients give their patients one ‘free’ missed appointment. The underlying rationale is obvious: Most patients become (unjustifiably) upset when they receive a statement for a missed appointment, so it makes good business sense to use discretion when deciding who should or should not be compelled to pay a missed appointment charge.
1 This sample is comprised of health care providers serving patients in more than one thousand different municipalities and cities throughout more than 30 states.
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