Navigating Medicare compliance remains a central consideration. Medicare participatory practices must not establish subscription payments for amenities covered by Medicare. HHS’ Office of the Inspector General (OIG) published the results of three investigations into the overcharging of Medicare patients; each of which are generally helpful guides for DPC compliance. In 2003, a settlement of $53,400 was reached for fees levied by a physician to patients for services covered by Medicare. The same charges were made against a North Carolina physician in 2007, and resulted in a settlement of $106,600. Most recently, in 2013, a medical group in South Carolina agreed to a settlement of $170,260, again for mandating relatively small annual payments from Medicare beneficiaries for “administrative” services that were deemed covered services (constituting an “access” fee). Failure to develop a Medicare compliant model can lead to significant financial and legal ramifications. We want to avoid physicians opting of Medicare to avoid this exposure. Solid compliance work can avoid Medicare compliance exposure without necessitating opting out of Medicare.
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