By Audrey Landers
Missed appointments, or “No Shows” as they are known among physicians, are a long-standing problem. Approximately 19% of patients will be no-shows, leaving an average of $195 worth of missed revenue per patient. The most popular way to encourage patients to show up and recoup losses from those who don’t is to charge for missed appointments. This is fine…if the patient is covered by Medicare. If they have Medicaid it’s another story.
Rules for Medicaid:
Federal regulations dating back to 2004 state that physicians who participate in Medicaid must accept Medicaid reimbursement as “payment in full” (42 C.F.R. §447.15). The Centers for Medicare and Medicaid (CMS) has interpreted this to mean that physicians may not charge Medicaid patients no-show fees, stating that missed business opportunities are a part of being in business and therefore should not be charged for. This policy is completely different from the one they have for Medicare.
Rules for Medicare:
Medicare’s rules for no-show fees are fairly straightforward. Any physician who accepts Medicare may charge missed appointment fees to Medicare patients so long as they meet the following requirements:
- The missed appointment policy must apply equally to all patients
- The patient must be made aware of the policy beforehand
- The fee amount must be the same for all patients
- Medicare may not be billed, instead the physician must bill the patient directly
A full explanation of the policy can be found in Chapter 1, section 30.3.13 of the Medicare Claims Processing Manual. This policy became first became effective in October of 2007.
CMS considers the no show fee to be a charge for a missed business opportunity, rather than a service. This is completely contrary to the previously stated opinion that, when referring to Medicaid patients, missed opportunities are an unavoidable part of doing business.
Another issue is to be had with the main rule in the Medicare policy, specifically their rule stating that the missed appointment policy must apply equally to all patients. If the policy must apply to all patients, does that prohibit physicians who see both Medicare and Medicaid patients from having a no-show fee?
SCG Health believes strongly that policies should be clear and leave no room for confusion. While we don’t necessarily have an opinion either way whether or not no-show fees should be allowed, we do hope that CMS will clarify their contradictory policies so that there is no confusion about what is and is not allowed.