Accepted Answer

As a physician who deals with the legal issues involved in medical billing on a constant basis, I would STONGLY suggest that you consult a local attorney who is familiar with health care law, and the anti-kickback provisions of the Medicare regulations.

The Office of Inspector General has a longstanding issue with third-party billing arrangments that are based on a percentage of collections because of concerns that such arrangements may increase the risk of upcoding.

It can be argued that it does not cost any more to bill an insurance company for a 99204 than it does for a 99203. If you are paid on a percentage basis, the incentive of course is to bill a higher percent of 99204.

Spending a few hundred (or more) dollars establishing a quality compliance program, and establishing a relationship with the medical practices that avoids legal issues with the OIG is litterally priceless. You don't want to spend months or years fighting civil and criminal charges related to your billing arrangments.

Expert:	FamilyPhysician
Pos. Feedback:	100.0 %
Accepts:
Answered:	4/8/2008

MBA, MD

Legal-medicine issues, business law principles, lecturer in medical-legal issues