Routine Wavier of Deductibles and Coinsurance Routine wavier of deductibles and coinsurance may result in allegations of false claims, and possible civil monetary penalties. Routine waivers may be seen as a means to gain referrals, which is a violation of the anti-kickback regulations. Wavier of deductibles, coinsurances and copayments are only acceptable if the waiver presents a clear financial hardship for the patient. It is recommended that written criteria, establishing policy to determine financial need, be developed. There must be a “good faith” effort to collect these monies. The effort to collect deductibles and coinsurances must be documented. The individual office billing practices will determine when a dollar amount is uncollectible. It is recommended that all copayments, coinsurance, and deductibles be collected, as far as reasonable, at the time of the service. Patients may request a statement of services, as published in the Medicare News Brief 99-3, April 1999. However, to avoid patient confusion and the possible collection of over payments, it is not recommended that routine statements, even if titled as a “non bill”, be sent on a regular basis. Patients often do not understand, or do not read, the statements in their entirety. This can lead to improper credit balances. In turn, this will create additional and unnecessary paperwork for the office, and if not corrected would be viewed by an auditor as a means to gain improper payments. Return to Contents | Return to Billing Compliance