I am going back and forth with my billing company in regards to placing the PR-45 amounts on patient statements/bills. They have mention that in compliance with the OIG we should still be charging the patient what the payer puts to patient responsibility, however, we are NOT contracted with many insurance companies. Therefore, my view is that amount they are referring to in the OIG is for contracted payers only and they are contracted to charge the patient their responsibility. We do charge the patient their deductible, copay, and coinsurance, but because we are NOT in-network, we do not leave them responsible for the amount over the allowable. Is this a violation, come someone give me an additional advice or guidance…

Thanks!