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Navigating Medicare Beneficiaries in Cash Based Physical Therapy

Can I charge a medicare patient a cash rate? Medicare and physical therapy often intersect in complex ways, leaving many healthcare providers puzzled about the rules and regulations. For physical therapy practice owners, understanding the intricacies of Medicare compliance and billing is crucial to running a successful business. One area that frequently causes confusion is whether it's possible to offer cash-based physical therapy services to Medicare beneficiaries. This topic has sparked numerous debates and questions within the physical therapy community.


Cash and Medicare Card

This article aims to shed light on the relationship between Medicare patients and cash-based physical therapy services. We'll explore the conditions under which Medicare beneficiaries can choose to pay out of pocket for their treatment. The discussion will cover important aspects such as medical necessity, the role of participating and non-participating providers, and the use of Advance Beneficiary Notice of Noncoverage (ABN). By the end, readers will have a clearer understanding of how to navigate Medicare regulations while offering cash payment options to their patients.


Can Medicare Patients Choose To Be Self-pay?

The ability for Medicare beneficiaries to choose self-pay options for physical therapy services depends on several factors. These include the provider's relationship with Medicare and whether the services are considered "covered" by Medicare.


For physical therapy practice owners, it's crucial to understand that Medicare patients can only pay cash for services that are "not covered" by Medicare. This includes services excluded by statute, such as wellness and fitness programs, or those deemed not medically necessary.


If the physical therapy is preventing or slowing a patient's decline and can't be safely provided by non-skilled personnel, it's considered medically necessary, thus a covered service. In such cases, providers cannot charge cash for these services to Medicare beneficiaries.


It's important to note that physical therapists cannot "opt out" of Medicare like some other practitioners can. The rules surrounding Medicare and cash-based physical therapy are complex, and practice owners should consult with a healthcare attorney well-versed in Medicare law to ensure compliance.


Is The Treatment a Service Covered by Medicare?

Medicare covers physical therapy services that are deemed medically necessary. This includes treatments for injuries, illnesses, chronic conditions like Parkinson's disease, and recovery from events such as falls, strokes, or surgeries. Medicare Part B covers outpatient physical therapy when certified as necessary by a doctor or provider. Additionally, Medicare covers occupational therapy and speech-language pathology services.


If You Are a Participating Provider

Participating providers face specific rules when it comes to Medicare beneficiaries and cash-based physical therapy. These providers cannot accept direct payment from Medicare patients for covered services, except for standard deductibles and copays. Instead, they receive reimbursement from Medicare.


Accepting Cash for Non-covered Service

For services not covered by Medicare, such as wellness programs or those deemed not medically necessary, participating providers may accept cash payments. However, it's crucial to clearly communicate this to patients and ensure compliance with Medicare regulations.


Advance Beneficiary Notice (ABN)

ABNs are essential tools for participating providers. They inform patients about potential financial responsibility for services that Medicare might not cover. Providers must issue ABNs before delivering services that may not meet Medicare's medical necessity criteria. This allows patients to make informed decisions about their care and potential out-of-pocket costs.


If You Are a Nonparticipating Provider

Non-participating Medicare providers have more flexibility with cash-based physical therapy for Medicare beneficiaries. They can accept self-payment at the time of service, but must still submit claims to Medicare. Medicare then reimburses the patient directly. Non-participating providers can bill up to 115% of the Medicare Fee Schedule. For services that may not be considered "medically necessary," it's mandatory to provide an Advance Beneficiary Notice of Non-coverage (ABN) before treatment. The ABN should include an estimate of the cost, and the actual payment should be within $100 or 25% of the estimate. This approach ensures transparency and compliance with Medicare regulations.


If You Have No Relationship With Medicare

For physical therapy practice owners with no relationship with Medicare, the rules are quite specific. These providers are considered "out of network" for Medicare beneficiaries. They can accept cash payments only for services not typically covered by Medicare, such as wellness and fitness programs. However, they cannot provide services that would normally be covered by Medicare.


Treating Medicare Patient as a Cash-Based Physical Therapists

To provide cash-based physical therapy to Medicare patients, it is crucial to have a comprehensive understanding of the regulations and compliance requirements. Practice owners need to be aware of the limitations on offering self-pay options to Medicare beneficiaries. Whether you are a participating, non-participating, or out-of-network provider, clear communication with patients and careful adherence to Medicare guidelines are essential for maintaining both legal compliance and patient trust.

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