Global Period – Compliance Question

On March 8th, 2011, posted in: Tips by

Some physicians in our practice like to extend the global period for surgical procedures in order to provide continued free care to patients because they believe the patient has some financial hardship. Can we do this?

NO. You cannot arbitrarily extend the global period of a surgical procedure to save the patient money. If you do not charge for those visits beyond the global period to help a patient out financially, you run the risk of noncompliance with a variety of statutes and regulations, including federal false claims and Stark anti-kickback laws, CMS coding guidelines and commercial carrier contracts.

If the patient needs financial assistance, you must dig out the practice financial policy and have the patient provide all necessary documentation to prove he cannot afford your charge, partially or in full. Keep the documentation in your chart and remember this ‘courtesy’ applies to the visit in question only. It should not be considered as a ‘forever’ forgiving policy. If the patient can only pay a portion of the bill, get it in writing and settle on a monthly payment that takes no more than 3 or 4 months to settle the balance.