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Excluded services and discounts

Looking for some guidance on this scenario:

We bill $ 528.00 on a certain procedure code to every insurance company (commercial or Medicare). Based on our individual agreement with those insurances, we write off the difference to get down to our contracted amount (when it is a covered service). However, there are some commercial companies that consider the procedure investigational and/or not a covered benefit, and deem it "non-covered" and patient responsibility.

Can we offer a discounted price to those patients whose insurance does not cover that procedure, as long as the discounted price is the same for un-insured patients?

My physician has concerns about us having "different fee schedules", however the way I see it, we have *one* fee schedule ($ 528.00 billed to all carriers), and we simply offer our own discount when it is non covered, rather than the contracted amount (or making the patient pay the entire amount).

I have tried looking for this on the OIG website, but so far all I have been able to find is reference to un-insured patients.

Any thoughts are appreciated, as well as any links to specific sites (including the OIG).

Medical Billing and Coding Forum