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Time of Service Discounts Explained

Compliance Basics
in Compliance Basics
By Team KMCU

Do you want to offer discounts to uninsured or partially insured patients?

We encounter offices daily wishing to offer discounts to uninsured or partially insured patients. With ever increasing premiums and deductibles, along with decreasing benefits, many patients being forced to cash pay more quickly or without coverage at all. To remain competitive in the market and make it more affordable for these patients, sometimes inappropriate discounts are offered. This is usually in the form of a so-called Time of Service (Bookkeeping Savings) discount.

Time of Service Discounts Explained

We commonly hear, “It’s my practice, I should be able to do it my way” Unfortunately, this is not the reality that we live in, especially as registered providers for many carrier networks. When it comes to Medicare and other federally funded programs, the rules must be followed precisely. When extending a Time of Service discount, first understand its intention and guidelines.

The discount must be defensible

The OIG has provided some great guidelines to follow here. These guidelines tell us that we can safely suggest that a 5-15% discount on services may be within reason. The elements that must be considered are to ensure the services are not being billed to a payer and are being paid the same day the service is being rendered. However, the most important issue to remember from this guidance is that the discount must be defensible, meaning truly reflective of the bookkeeping savings.

First, qualify the chosen percentage. Consider what it really costs to bill the patient or insurance, rather than to collect your fee at the time of the service. Once the established percentage of savings is decided, create written policy and procedure to be followed. Provide this option in your office financial policy so the patient can be properly notified. Consider including such things as rules for payment, instructions for self-submission, if applicable, and a reference to governing guidelines that the practice is following to compliantly offer time-of-service discounts.

Your fee is your fee

As an out-of-network provider, if you offer the patient a superbill for self-submission, you must provide that bill with the fee the patient paid at the time of service. Remember the rule “Your fee is your fee”? You will first list the service provided at your office fee, then you will reflect the percentage of discount as the following line item to demonstrate that the patient received a discount; therefore, the payer can see the actual cost of the service for the patient.

Always check your state laws for additional guidance on this topic before proceeding. When your state law is stricter than a federal law, the stricter law prevails.

Remember, when your actual fees are robust, and you would like to offer larger discounts than the OIG guidelines, KMC University recommends utilizing ChiroHealthUSA, a network associated with a Discount Medical Plan Organization. In this model, you can set your discounted fees at your desired rate, offering this option to uninsured, under-insured, or partially insured patients, such as your Medicare patients. For more assistance on this topic or with the Discount Medical Plan option, contact us at or 855-832-6562