ASC Fee Schedule
Best Practices: Tip #4
In our three previous tips on fee schedule best practices, we discussed auditing your fee schedule to determine if fees are in line with contract reimbursement allowances, how to decide when and how much to increase fees, and what amount to assign as your baseline fee.
This week, in our final tip in this series, we are going to discuss the importance of documenting your fee schedule changes. Whether you increase your fees across the board or focus on making specialty- or procedure-specific changes, record any changes you make to the fee schedule and how you arrived at the changes. Print out the adapted fee schedule, write down the reason for the fee change next to the corresponding CPT codes and place the document in a notebook to be stored with your policies and procedures.
Tip #4: Documenting Fee Schedule Changes
The following are suggestions of the documentation to maintain when implementing fee schedule changes:
- Original fee schedule
- How you treat multiple procedure discounts
- Items included in your procedure fee (e.g., labs, EKGs)
- Fees carved out at a higher or lower percentage than an across-the-board percentage
- Fees for implants (HCPCS codes and non-specified implants)
- Explanation of how you arrived at the new fee schedule. Are the updated fees a percentage over Medicare reimbursement? A percentage over cost? A combination of the two?
Be specific when noting the percentage increases and how you calculated them. It may be difficult to remember the reasons and mechanisms you used when you changed your fee schedule, especially if it's reviewed only once a year. Your governing board will appreciate detailed recordkeeping when deliberating on increasing fees.
Keeping meticulous notes also makes sense from a compliance standpoint. Medicare will likely be more tolerant of fee increases when it sees documented proof that the changes are rational and consistent to all payers.
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