Waivers and Discounts: What are They and When do They Apply?

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C.Trey Scott, Coordinating Attorney at Kennedy, Attorneys & Counselors at Law leads this webinar. Waivers and discounts are normal business activities that occur throughout the US daily as a way to reward customers or to assist when an invoice or bill may too expensive. However, in a healthcare context, the normal rules for waivers and discounts don’t apply. This presentation will highlight what waivers and discounts are, how they work, and when they are problematic/illegal.

This webinar will cover the following objectives:

1. What waivers and discounts are and will be given examples

2. When waivers and discounts can be used to assist patients

3. When waivers and discounts can be considered illegal under Federal law

• 56:54

SUMMARY KEYWORDS

discounts, waivers, provider, ultimately, patient, trey, false claims, healthcare, false claims act, financial hardship, offer, compliance, discuss, billing, occur, situation, professional courtesy, medicare

SPEAKERS

Catherine Short, Trey Scott

Catherine Short  00:00

Welcome to our continuing educational webinar series. I am Catherine Short Partnership Marketing Manager for First Healthcare Compliance. At First Healthcare Compliance, we help you with a comprehensive compliance management solution tailored to your business, a hospital, hospital network healthcare practice of any size billing company or skilled nursing facility, and we help you manage every aspect of a compliance program. And our training library provides hundreds of modules that are easy to assign and track. As part of our complimentary educational webinar series. We bring you experts from around the country to discuss relevant topics in the health care industry.

Catherine Short  00:45

We are so pleased to have Trey Scott, Coordinating Attorney at Kennedy Attorneys and Counselors At Law back with us today. Trey received his Bachelor of Science and Master of Business degrees from Texas Tech University and his JD from Texas Wesleyan University School of Law, now Texas A&M University School of Law. While in law school, Trey was a member of the Arbitration Competition Team as well as a Student Bar Association Representative. He also was a law clerk for the 106 District Court of the State of Texas.

Catherine Short  01:26

Trey has a significant experience in health care law. This experience includes Medical Malpractice, litigation, administrative and regulatory appeals and disputes, professional board matters and overpayment disputes. Trey is licensed to practice law before Texas State courts as well as the United States District Courts for the Northern Southern Eastern and Western districts of Texas. Trey is also licensed to practice before the United States Court of Appeals for the Fifth Circuit.

Catherine Short  02:01

A copy of the slides is available for download on the control panel. Feel free to submit questions into the question box on your control panel. During the presentation, we will address questions at the conclusion of the presentation. Your PAHCOM And PMI CEU certificates will be emailed to you. Following the broadcast, your PAHCOM certificate will come directly from PAHCOM and your PMI certificate will come from our email. There is no need to request either one.

Catherine Short  02:31

Additional CEU opportunities will be available to BC Advantage members following live broadcast, see their website for details.

Catherine Short  02:40

So Trey, welcome, and thank you so much for being here today. We sure  are excited to have you back. Thank you so much.

Trey Scott  02:50

Yes, thank you, Catherine. And thank you to First Healthcare Compliance for allowing me to give this presentation. And thank you to everyone that is out there listening and following along. I definitely appreciate the interest in this topic. And this is a topic that it’s somewhat complicated, and it has a lot of nuances. And that’s what we’re going to be discussing. It may not be as deep on some areas. But if you have questions, and you want to go a little bit deeper on some of these areas, please reach out to Catherine or please reach out to me through the contact information. And I’ll be happy to answer those questions. And feel free to submit your questions in the question box. And I’ll get to as many of those as I possibly can. And yes, so let’s let’s get started.

Trey Scott  04:00

Today we’re going to be talking about discounts and waivers. What are they and when do they apply? As Catherine stated, my name is Trey Scott, and I am the Coordinating Attorney with Kennedy Attorneys and Counselors At Law in Dallas, Texas. We are a health law boutique. That means that the only area of law that our firm practices is health law. The firm has, I tried to think, I was gonna say the amount of combined experience we have, but I do know it’s, I do know it’s a lot. It’s over 50 years of combined experience in health law so whenever it comes to practicing health law, the attorneys at the firm, we like to think we know what we’re doing, and we have the experience to back it up.

Trey Scott  05:05

So let’s just talk about where we’re going today. What this presentation, we’re going to be discussing what is a waiver or discount, and then we’re going to be discussing when waivers and discounts might apply. And probably the most important question, and this is the question that a lot of y’all want to know. And that’s, are they legal? We will be discussing all of that. Now, as stated, my name is Trey Scott, a coordinating attorney, my contact information is below. Like many of you, out there, I am currently working from home. And so the best way to reach me if you want to discuss topics that we discuss here, that would be either email, which is trey@markkennedylaw.com or reaching out to me at my direct line, which is there as well. If you want, you can call the office and then the call can be routed to me. But more than likely, the best way to get me is going to be my direct line or on email. Now, I’m going to apologize in advance. As I stated, I am working from home. And if you know anything about working from home, you know that sometimes you’re unfortunately interrupted by your feline and dog friends. So I happen to have both in the house with me right now. And they do take a lot of naps. So I wish I could say that I got to join in with the naps during the day. But that actually isn’t the case. If you do hear background noise, I apologize in advance. It’s just the furry friends doing they’re doing their thing. So what’s Catherine mentioned some of the experience that I have just touched on it briefly to give you an idea of what I’ve what I’ve seen. I’ve represented multiple clients in cases involving the Department of Justice, HHS, OIG, Texas Health and Human Services Commission.

Trey Scott  07:48

Yes, so represented clients and those investigations and productions. I’ve also done medical malpractice defense with an am law 100/global 200 firm represented hospitals and nursing homes and medical malpractice cases. I’ve represented providers before multiple boards, including medical nursing, professional counseling, dental pharmacy boards, I have quite a bit of experience, because this tends to be the area that I get a lot of cases in representing providers and UPIC and ZPIC appeals, including statistical sampling and extrapolation overpayments. And then finally, I’ve represented providers and Medicare and Medicaid revocations, suspension matters, and also exclusion matters.

Trey Scott  08:56

So now let’s get into the presentation. What is a waiver or a discount? Well, it’s pretty much what does he sound like? A discount is a reduction in the amount owed to a provider by a patient. waiver, by contrast, is when a provider intentionally decides not to pursue collecting a debt or payment from a patient for services. Now, you see these all the time in the course of normal business activities. And whenever I say normal business activities, I mean, every other business out there, aside from healthcare, because healthcare is kind of its own industry. So we’re not going to be including healthcare in normal business activities. So like a sandwich place that you go to multiple times, you get a discount on your sandwich or, for example, Starbucks, if you collect a certain amount of stars or points, I can’t remember what they’re called, you end up getting a free coffee after a certain number. So that is an example of a labor in a discount in normal business activities, normal business operations.

Trey Scott  10:38

Now, what is an example of a waiver and discounts in health care activities, that would be charging a different price for a cash visit, instead of submitting the claim to insurance, and just a heads up? Whenever I refer to insurance, I’m going to be including Medicare and Medicaid in that term, I’m not going to differentiate between commercial insurance and governmental health programs. Another example of a discount would be charging a patient a reduced price for multiple, multiple tests. For example, you have a patient that comes in and they’re experiencing symptoms, and they need a COVID test, they need a flu test, and also you want to test for strep, you would offer a patient a reduced price for multiple tests. Now, one other caveat, these examples that I’m providing right now, aren’t examples of whether art, shall we say, examples that could be considered legal that’s that we’re going to discuss that in a different slide. These are just examples of waivers and discounts that we have seen that we have heard about in our area of practice at the firm. And finally, discount is essentially any mechanism, mechanism or action that reduces the amount owed by by a patient, again, a discount, fairly obvious labor would essentially be seen both a parent and their child and only the billing for the visits for the parent.

Trey Scott  12:45

And then another example of a waiver would be not billing for a patient because you believe you will be able to collect the money. So those are some examples of waivers and discounts. Now, when would discount applies, now discounts can and there is a caveat there apply in a couple of settings. And this list here is not exclusive, there may be other. There may be other examples of when a discount can apply. But these these are the areas that we have seen them to apply whenever and you get not as much pushback from the government or other insurance carriers. So discounts can apply in a couple of settings. For example, when a cash discount is offered to patients. Now, a issue there would be that you don’t need to discount provide a cash discount. So for that you undercut your own contracted rate with insurance carriers because then you may get into an issue with your insurance carrier. And that would not exactly be a fight you would want to have to deal with. Another example of when a discount would apply would be when a provider discounts a co payment to the amount a patient would be charged after the provider receives payment from insurance and Medicare as opposed to the use of usual and customary charge. An example of this would be for example, the usual and customary charge being $2,000 for a service, but you know insurance slash Medicare I would pay $1200 of that, well, you, you would end up charging the patient, their percentage of a co payment of the $1200. That would be an example of a discount. And then finally, when a provider offers discounts to a select few patients due to extreme financial hardship, and that does exist, and unfortunately, due to the world we currently are in financial hardship has been more prevalent than ever for some individuals. Now, I’ve discussed a few of the caveats. But there are caveats to these, hence the asterisk. It’s honestly safer and less risky for a practice to offer no discount, that always is the best approach. If you’re not doing it, then there’s nothing to investigate. And then, for example, on the extreme financial hardship, you’re going to have to get financial information from the patient that would show that there is a financial hardship that could be providing, getting a budget from the patient, a tax return multiple, multiple financial documents would spice but you need to get that documentation to show that a financial hardship actually exists. Now, when would waivers apply, waivers can again apply and a couple of settings of waiver would be a preferred apply, possibly apply in a professional courtesy situation. For example, you see another doctor in the community and you end up leaving the leaving the co-payment due to the fact that this is a doctor in the community. And as a professional courtesy, you waive that.

Trey Scott  17:35

Waivers could also apply for a safe harbor. That would be a situation where you do not believe you’re going to be able to collect the debt, and you go through a process of waiving that bad debt off. And then finally, waivers can again apply in a situation of financial hardship. Now, just like I discussed previously, there are some caveats to this. And one caveat would be financial documentation would be required to waive for a financial hardship. That is just something that has to be provided. If you are going to have a patient claim a financial hardship, they have to document it, and it has to be in their own writing, and it has to be in their own documentation. It’s not something that you can just say, Oh, well, I believe you. And we’re going to we’re going to waive this, there has to be documentation just like everything else in healthcare. If the documentation isn’t there, then it doesn’t exist. So you have to have financial documentation to show a financial hardship. And for the Safe Harbor. As I stated they there are certain requirements that have to be met in order for a Safe Harbor waiver to apply.

Trey Scott  19:37

And then finally, a professional courtesy should not be extended to those that can or could potentially refer patients to the provider. If you give a waiver to a provider that in turn can end up referring patients to you, then you start getting into a situation where you could be violating a lot, several different federal laws involving Medicare, Medicaid, if it’s an instance of a commercial commercial payer, you also could get in a situation where you can be violating some some laws regulations there. I know Texas HHSC has been pursuing instances of improper kickbacks and things of that nature with commercial commercial insurance. Sorry, not Texas HHSC, sorry, Texas, Office of the Attorney General. My apologies. They have been pursuing instances of what is deemed illegal referrals and kickbacks and commercial payers.

Trey Scott  21:11

Now, are discounts and waivers legal?  Short answer, yes. They, they are. Longer, more precise answer is? Yes, but it depends. In some certain instances, they are perfectly legal. But overall documentation is needed, for example, in the instances of financial hardship, and overall, their overall considerations that need to be made, whenever you are considering discounts or waivers. Now, why? Why are, why this long answer whenever you said that, yes, in some instances, they aren’t allowed? Well, I would hope this is something that all healthcare providers are aware of. But the reason it is it depends is because federal law, that’s the False Claims Act, for example.

Trey Scott  22:28

If you’re unaware of the False Claims Act, essentially, it boils down to that it is illegal to submit claims that a provider knows or should have known are false or fraudulent, that’s big, they should have known, because it’s assumed that every claim that is submitted by a provider’s office, the provider has signed off on and that the provider is aware that that claim is is going to be submitted and they signed off on the claim and it is good to go. So that’s where they should have known false or fraudulent comes in. Again, example of this would be if you were to take a cash payment for services, and then you were to bill Medicare, for that cash payment. That could be a false claim. And as far as what you were facing with false, this False Claims Act, you kept it the False Claims Act may result in fines up to three times the Medicare or Medicaid loss plus $11 per claim filed. Now an example of this, we’ll just do the math really quickly here, you build 10 false claims that you know that the provider knows or should have known were false or fraudulent. The loss to Medicare on the claims is roughly $2,000. just picking a number out of a hat. Preble multiplier, the three times multiplier brings the loss to Medicare to $6,000. So whenever it’s saying three times you multiply, you multiply the loss times three, it used to be doubled, but then they upped it to triple and then you have to calculate the $11,000 per claim. So since there were 10 false claims, that’s 11,000 times 10. The 10 false claims that brings it to $110,000, and the total penalty if I did my math correctly. Which I believe I did. It brings the total penalty to $116,000 for just 10 false claims. And in addition to that the False Claims Act has some provisions are there also is a criminal False Claims Act, my apologies, it can be found at 18 USC section 287. And the penalties for the criminal False Claims Act include fines, additional fines in addition to the civil action and or imprisonment. And I know this some of you are probably wondering this, yes, you can have a situation where you are actions are pursued against you civilly and criminally, the information I’ve discussed in the first two full bullet points. That’s the civil False Claims Act and the criminal false claim act can like I said, include fines and or imprisonment. Those can be pursued together. Now, the situation that normally applies whenever it comes to discounts and waivers is the Anti Kickback Statute. Now, this is whenever a provider, or this applies whenever a provider knowingly and willfully pays remuneration to induce or reward individuals, for patient referrals or for the generation of business.

Trey Scott  26:54

Now, go back to what I said earlier. In normal business activities, giving people a referral bonus is a standard accepted practice. For example, I signed up for HBO, Max to watch the new Wonder Woman movie that came out. And shortly thereafter, I got an email that said that if I were to refer someone to HBO Max, then I could get a month free. You see that a lot. Oh, you see it a lot with cable companies as well. Sign up for AT&T and you get a discount on your next bill. That in normal business is accepted. However, in healthcare, because healthcare is built on the premise, whether it’s correct premise or not, but healthcare is built on the premise that providers or that patients should be able to choose their provider. Whenever you are offering things, whenever you are offering renumeration to induce or reward individual for referrals to get patients to come to your business, that is seen as taking choice out of the equation. And that, again, since healthcare is built on the premise of patient choice, that is not seen favorably.

Trey Scott  28:57

Now, renumeration includes anything of value and can take many forms. Many forms beside cash. I know some examples of that are offering hotel rooms for people to refer patients offering directorships to physicians or other health care providers to refer patients. It can it can include free rides. Now there’s a caveat with the free rides as in some situations, it may be allowed, but it offer includes offering free rides to a provider if it essentially includes anything that can be seen as a reward, to get patients to come to your practice. Now, go back to the example I said earlier of offering the professional courtesy to a provider in the community. Yes, that individual that you offer the professional courtesy to can refer patients to you, then it can be this that can be seen as renumeration and with in violation of the Anti Kickback Statute. So that’s why discount or waivers, those can possibly be seen as remuneration. So you have to be very, very, very careful in that context. So what are the penalties for the anti kickback statute, they include jail terms, fines, and ultimately exclusion from participating in the federal health care programs.

Trey Scott  31:03

And finally, the last one we’re going to talk about is the physician self-referral law, which everyone knows as Stark. It ultimately prohibits referral to physician or family owned entities for designated health services. Now, there is a long list of what can be considered designated health services, it’s multiple, multiple things that, ultimately, are standard practice in healthcare. And they are, that unfortunately, can be seen as illegal. Now, this is not as common whenever it comes to discounts or waivers. But ultimately, it still could occur. And that’s why it has been why it has been. Now penalties for start include fines as well as exclusion from participation in the federal health care programs.

Trey Scott  32:20

Now, you’re probably wondering, what can apply whenever it comes to commercial insurance providers? Well, like like I said, the Texas Office of attorney general has pursued illegal kickbacks, Stark violations, and also False Claims through through commercial insurance, and has ultimately sought penalties against providers in in Texas for doing those those things illegally. Even though they weren’t billing, Medicaid, and they weren’t billing, Medicare, they were just billing commercial insurance providers. However, the Texas Attorney General still opened an investigation and brought charges against these individuals.

Trey Scott  33:25

And now, we will go to ultimately, we will go to questions. I know, this is been a little bit of an overview. So if you have any questions, I hope as you were going along, you were able to submit them through the portal to ask Catherine and I now turn it over and look forward to your questions. If I don’t get to your question. Remember, feel free to reach out to me. And I’ll happily answer it reach out to Catherine. She will forward it on to me, and I’ll try to get as many of those answered as I possibly can.

Catherine Short 34:22

Thank you so much, Trey. That was a really great presentation. And we do have a few questions here. So the first one is, you mentioned there is a long list of designated health services. Can you give us some examples of designated health services?

Trey Scott  34:45

Yes, that is a good question. I apologize. I muted myself. Oh, that’s a second. But yes, there are multiple things that can be considered a designated health services. Why? Like I said, it pretty much encompasses all of all of healthcare and it’s ultimately a lot of a lot of things. Designated Health Services could be, a critical lab services, it could also be DME, radiology and other imaging, home health services, outpatient, prescription drugs, inpatient services, it ultimately can be a lot, a lot of different things. So it’s very important to think of that whenever you’re potentially referring something to a entity that is owned by you or your immediate family member.

Catherine Short  35:55

Okay, all right. And in the first place, how would the OIG, or the DOJ, or or any other agency, how would they find out in the first place that discounts were occurring? I mean, how would they even know?

Trey Scott  36:12

That is a very, very good question. Thank you for asking that. That is one thing that whenever I was putting this presentation together, I ultimately was going to go into discuss, but I ended up leaving it out, because I wasn’t quite sure on time. But thank you for thank you for mentioning it. There are a lot of different ways that a agency can find out about discounts. And or waivers. One of those is through audits. Now, I don’t know how many of you have had to deal with an audit, probably everybody on the line has had to deal with an audit. And if you haven’t had to deal with an audit, just wait. They will be coming whether they’re through an insurance, commercial insurance carrier or through a uniform program integrity contractor, such as Clarence out of Dallas that are a large, UPIC for Medicare and Medicaid, what they’ll do is they will submit a documentation request, it could be a random audit, or it could be a targeted audit and audit based on information they receive. And they will submit a request for patient list. And then they will ultimately review the medical records, which goes back to the comment. If it isn’t documented, it didn’t occur. So just keep that in mind. If you ever have an audit, and First Healthcare Compliance can help take care of making sure you have policies and procedures and other programs in place to make sure documentation exists. And you know what to do in that context? It can, it could occur through the audits where, like I said they request to records review and then ultimately determine whether the proper amount was billed or if a false claim exists, or ultimately, just things of that nature.

Trey Scott  38:48

The most common way that waivers and discounts are discovered is through whistleblowers. Now, statutes make it clear that whistleblowers tmb or arc entitled to a portion of what is recovered if they go through what’s known as the qui tam process. So waivers and discounts may be discovered through whistleblowers, or they could be discovered just through a simple complaint to a to HHS-OIG. On HHS-OIG’s website. They have a submission form where if you know of what’s what they call fraud, and or waste, you can submit a tip to them. So that is where a lot of these investigations get started. They start with a complaint and then you receive a subpoena and or, for a civil investigative demand from the Department of Justice, or from HHS-OIG, and ultimately, they determine whether discounts and waivers and waivers occur. And so that’s that’s how a lot of them that’s that’s how a lot of waivers and discounts, discounts occur.

Trey Scott  40:30

Honestly, they also could occur simply from word of mouth, if word gets out that you are offering discounts to patients, then somebody is going to talk to somebody who’s going to talk to their cousin who ultimately works with health care, works in a healthcare context with HHS or with a state healthcare provider, and they are going to talk to their superiors and say that an investigation so that’s ultimately how these discounts and waivers occur, are found out. So you’re saying basically, it’s a small world. Basically, it is a small world, if it’s being done, it can occur. Oh, and one thing I forgot to mention mentioned, it can also be a provider in the community that tips off the tips off the agency, because if a competing provider finds out that you are giving a discount, what more would they like them to get rid of a competitor and ultimately get some of their patients, we have seen this in a health care in a home health context occur quite a bit, that if they discover something is being done, if one provider discovers that discounts are being offered, then they will tip off the regulatory agency. And that’s not something you want to have to go through.

Catherine Short  42:31

Okay. So, in light of these things, should providers give discounts or waivers? What are your thoughts on that?

Trey Scott  42:46

That depends. Ultimately, cash discounts and financial hardship discounts waivers, those tend to be the safest in by safest, I mean, those tend to be the ones that have ultimately been determined to be legal, without question. However, it’s not something that should honestly occur in every situation. And the least risky situation is to not offer waivers or discounts. And the reason I say that is because ultimately, you are not going to be the one to determine whether a waiver or discount is legal. It’s going to be up to the end of this, it’s unfortunate what the how this how this is being said, but ultimately, it’s up to the agency that is prosecuting you or is bringing a civil action against you. It’s ultimately up to their interpretation as to whether this waiver or discount applies. So the least risky approach is to offer no waivers or discounts. And the one that has ultimately been found to be acceptable is the ones that have been found to be the most success. Acceptable are the cash discounts and the financial hardship discounts/waivers.

Catherine Short  44:47

If you looked at a spreadsheet of different discounts and waivers that were given do you know offhand, off the top of your head, what types of facilities are usually giving more more of them?  Or if they are smaller or larger? Or, what has been your sense? Or do you know that by any chance?

Trey Scott  45:24

I know that in a context, the smaller of the smaller facilities tend to provide the cash discounts. Just because it’s easier to, it’s easier to keep up with, they offer a cash price. And if you don’t have insurance, or if you are just able to pay cash, then that’s what that’s what’s provided. But whenever it comes to the larger institutions, that’s whenever the like your hospitals, or your surgery centers, that’s where the financial hardship, ultimately, we see that waiver discount a lot because they’re able to, they’re able to put together a committee to review your financial documentation and ultimately reach a consensus as to whether a hardship does in fact exist, and what they can do about that financial hardship and what they wouldn’t be able to ultimately, ultimately charge and financial hardships, discounts and sorry, waivers and discounts, we also see those in a context. And this is a context that you never really want to see. Ultimately, if there is a bad outcome. And we say that in hospitals, ultimately, or surgery centers, if there’s a bad outcome due to negligence on the part of people involved, then a discount slash waiver could be offered. But ultimately, it would need to be offered off of the total bill not off of any particular service that and there’s a lot of procedures that have to be followed on in that context. So that that one really depends, but we kind of see it with both small providers. And going back to your question, we can’t see it what most small providers and large providers it just ultimately, the waivers and discounts are different as to what’s offered.

Catherine Short  48:10

Okay. And if so, this question came in, if we do give discounts and waivers what what should we do?

Trey Scott  48:22

Make sure the recipient pool that discount or waiver is given is small. If a discount or waiver tends to be a standard business practice, then that really is going to raise a red flag, for example. There was a physician that was giving waivers and discounts to patients and ultimately that ended up that ended up with them giving or getting unnecessary treatments and having a very high utilization rate. And then the government ended up bringing false coins and anti kickback actions against the provider and the provider is now having to having to deal with that. So that’s something that you really need to be aware of is making sure that the recipient pool of this, of the waivers and discounts are small. And you also need to have policies and procedures in place regarding who qualifies for these discounts and waivers. That way it’s set in stone. And it’s not going to be a situation where it’s left up to the west up to the provider to ultimately determine who qualifies. And also if a discount or waiver is given, then you need to have policies and procedures in place to determine what happens with what happens with that claim to make sure the claim isn’t submitted incorrectly, in would lead you to get a situation where a false claims violation occurs. So that’s, that is my recommendation on that if ultimately discounts and waivers are given. I’ll recap that make sure the recipient pool of those discounts of waivers is small, and make sure you have policies and procedures in place to document what occurs. And real quick, yeah, oh, no, sorry, I was gonna say, in real quick. If you look at your slides, I have sources for everything I talked about today, that’s going to be on your PDF, copy that you’ve got the presentation, and there’ll be details on that.

Catherine Short  51:14

Okay, thank you. Thank you. Is there ever some kind of situation where perhaps the practice or the facility is giving so many discounts that perhaps it could be argued that that is the actual price that is the new price? That that’s not actually a discount? But that’s the actual price? You know, what I mean?

Trey Scott  51:37

I do, I do know what you mean, that’s, that’s an interesting question. And ultimately, that that would be that would be yes, that would be the new, the usual and customary price, and it technically wouldn’t be. Right? Right. It would, it wouldn’t be seen as a discount, but ultimately, you still run into the issues of it, potentially causing for over utilization. And the providers, the providers numbers are going to be out of are going to be out of whack compared to that of their peers. So that is going to raise some red flags.

Catherine Short  52:28

Right. I wondered about that, too. If the numbers are then almost like, I don’t know, not like union, but you know, they are compared to people in their area and to their peers, to see if they are in keeping with the standard rate in their area in their group, etc. Is that, that’s true?

Trey Scott  52:50

Right, right. Yeah, yes, yes, because I mentioned it previously, but the you pick the uniform program integrity contractor, that’s all they do. They all they do is look at, look at claims and audit, do audits of claims that come in on their own, and then they will send audit requests to providers, but also they look at utilization rates, and ultimately determine how a provider fits in with their respective peers and geographic in a geographic area. And if you are leading the nation in a certain utilization and the person next to you is significantly below that, then that’s really going to raise a red flag. So yes, that’s, that’s something to be concerned about. Okay.

Catherine Short  53:53

Okay. All right. Very good. Well, thank you so much, Trey, did you have any other words of advice or anything else that you wanted to leave with us today?

Trey Scott  54:03

No, other than feel free to again, feel free to reach out to me if you have any questions, reach out to Catherine if, for some unknown reason you forgot my contact information or don’t have it handy. And also, check out all the great presentations that First Healthcare Compliance has they have a lot of great presentations out there on a multitude of different areas. So just spend some time exploring. I’m sure there’s something even the provider that has been practicing for many years, I’m sure there’s something out there that a provider can learn that would ultimately help their business and thank you again for your time. I definitely appreciate it. And thank you, Catherine and First Healthcare Compliance for having me.

Catherine Short  55:09

Well, thank you so much, Trey. And yes, that’s true, we do have quite a bit of information. So we have, especially on our YouTube channel, which you can look up, you can either find the information on our website at 1sthcc.com or on our YouTube site, which you just look up on YouTube, first health care compliance, and we have a lot of different, playbacks of our webinars there. And we have some other ones with Trey Scott. And we also have on our website, some great information, and we have some blogs and ebook and everything with Trey Scott as well, which I’m sure you would love to take a look at. So thank you so much for being here today. We really appreciate it. So thank you.

Trey Scott  56:07

Yes, thank you again, I definitely appreciate it.

Catherine Short  56:11

Yes, and attendees. Thank you so much for attending as well. And please use the contact information on the screen if you have any further questions and if you send us any questions later will forward them on to Trey. Please remember your PAHCOM and PMI CEU certificate will be emailed to you from within two days following the broadcast. There’s no need to request it. You can register for future webinars or request a demo of our compliance solution on our website at 1sthcc.com or call us at 888-543-4778. And thank you for joining us.

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