Invoicing for Services

[trophyhusband]

---

Members do not see this ad.

So this is a new thing to come up with the wife's PP that she's not quite sure how to handle. One of the departments of a local University wants to send at least one student (and potentially more eventually I guess) to her PP and they will pay her normal fees. But she has to send them a bill/invoice. She usually provides a superbill to patients but as this department is not the actual patient we're not sure if that's a good idea. Would an invoice be better with no identifying info of the patient be better? Does it matter since the department already knows who the student is since they're sending them?

Thoughts?

 

[dl2dp2]

The identity of the patient to the third-party payer is protected by HIPPA, so there's no need to submit an anonymous invoice. If you really are concerned you can ask the university to send you a patient ID/group number and identify the patient that way.

There are guidelines for claims submitted to third-party payers in general, and they often contain other HPIs such as diagnosis code and date of service. *All of that* is HIPPA protected and transmission of the information is governed by the relevant regulations.

 

[trophyhusband]

The identity of the patient to the third-party payer is protected by HIPPA, so there's no need to submit an anonymous invoice. If you really are concerned you can ask the university to send you a patient ID/group number and identify the patient that way.

There are guidelines for claims submitted to third-party payers in general, and they often contain other HPIs such as diagnosis code and date of service. *All of that* is HIPPA protected and transmission of the information is governed by the relevant regulations.

HIPAA applies to health insurers, clearinghouses, and providers who accept insurance/use the clearinghouses. The University department isn't a covered entity as far as HIPAA is concerned (I wouldn't think) and as my wife's practice is cash only it is also not a covered entity. So I don't think HIPAA applies here but feel free to disabuse me of that notion if that's incorrect somehow.

But having them provide a unique identifier for those patients that she could put on an invoice is a good idea so I'll tell her to have them create that and keep a list for themselves.

 

[TexasPhysician]

I’d have the students sign something to the effect that the university has full access to the records. The school may claim that a patient wasn’t seen and request an audit. Will they cover no-shows? If not, I’d bill a higher rate to compensate for eventual missed visits.

 

[dl2dp2]

HIPAA applies to health insurers, clearinghouses, and providers who accept insurance/use the clearinghouses. The University department isn't a covered entity as far as HIPAA is concerned (I wouldn't think) and as my wife's practice is cash only it is also not a covered entity. So I don't think HIPAA applies here but feel free to disabuse me of that notion if that's incorrect somehow.

But having them provide a unique identifier for those patients that she could put on an invoice is a good idea so I'll tell her to have them create that and keep a list for themselves.

It depends on how you interpret the word "claim". If you wife ever sent a receipt which is used by an insurance company to write a claim for a patient to receive out-of-network reimbursement, then she would be considered a covered entity.

It's always safe to follow HIPPA than not, and universities are for sure business associates of covered entities, and therefore they must also follow HIPPA. If the university leaks PHI without authorization and it caused harm, they are liable for performing remedy. Of course, it's always better to make patients aware of this before proceeding.

The issue with anonymous invoicing is very often third-party payers don't reimburse such claims. My experience has been that self-insured entities like universities are even more bureaucratic than insurance companies w.r.t. these things.

 

[trophyhusband]

It depends on how you interpret the word "claim". If you wife ever sent a receipt which is used by an insurance company to write a claim for a patient to receive out-of-network reimbursement, then she would be considered a covered entity.

It's always safe to follow HIPPA than not, and universities are for sure business associates of covered entities, and therefore they must also follow HIPPA. If the university leaks PHI without authorization and it caused harm, they are liable for performing remedy. Of course, it's always better to make patients aware of this before proceeding.

The issue with anonymous invoicing is very often third-party payers don't reimburse such claims. My experience has been that self-insured entities like universities are even more bureaucratic than insurance companies w.r.t. these things.

Just an FYI but I believe the bolded is incorrect. In order to be a covered entity you need to be paid by the insurer directly. If you provide a superbill and the member is reimbursed by the insurer it does not make you a covered entity. The test is if you or someone on your behalf (a clearinghouse) submit the claim for reimbursement then it's HIPAA covered but if the patient submits the claim for their own reimbursement it does not qualify.

I agree that the University itself is a business associate as far as HIPAA is concerned with their various insurers but I don't know that it matters in this case. The bureaucracy is a concern too so she's still trying to figure out if this is even worth it.

 

[trophyhusband]

I’d have the students sign something to the effect that the university has full access to the records. The school may claim that a patient wasn’t seen and request an audit. Will they cover no-shows? If not, I’d bill a higher rate to compensate for eventual missed visits.

Good idea on the waiver. I can put that together fairly quickly.

And thanks for the no-show note. She charges for no-shows normally but we'll get it in writing from the department that they'll pay for it or she won't bother. Or like you said negotiate a higher rate.

 

[trophyhusband]

For added context the department is the athletic department so the students in question are theoretically motivated more than most to maintain their scholarship or stay on the team. But they of course get depressed or whatever like anyone else.

There wasn't really any reason to be so vague in the original post.

 

[TexasPhysician]

Good idea on the waiver. I can put that together fairly quickly.

And thanks for the no-show note. She charges for no-shows normally but we'll get it in writing from the department that they'll pay for it or she won't bother. Or like you said negotiate a higher rate.

I have a contract with 1 entity that won’t pay for no-shows. I charge 33% higher, and they were fine with it.

 

[trophyhusband]

I have a contract with 1 entity that won’t pay for no-shows. I charge 33% higher, and they were fine with it.

Just to close the loop on this they agreed to pay no shows/late cancellations rather than the higher fee. Which is fine by us. Thanks for the tip as we wouldn't have thought about it until it happened.

She sees her first student today so we'll see how the first reimbursement goes.