That’s a bigger problem than you may realise, says accountant David Dahm.
If the Department of Health, Disability and Ageing approaches assignment of benefit rules like the PSR approaches potential Medicare misuse, then it could potentially be kissing any chances of a 90% GP bulk billing rate goodbye.
That’s according to David Dahm, an accountant largely servicing general practices.
“Everybody says, ‘you’re overplaying the concern, Mr Dahm’,” he told The Medical Republic.
“I say, ‘well, I’ve been told that about payroll tax … and what happened?’
“The law is very specific. If you don’t have a signature, it’s pretty simple – you run the risk of being accused of not validly billing Medicare.”
The complexity of the assignment of benefit system – specifically, the new requirement for practices to store a copy of the patient’s consent for each episode of bulk billed care – is such that there are multiple potential breaking points.
If a patient leaves without signing, or completes a pre-assignment but then scope of the consult changes, or they see another GP, are all instances where Mr Dahm says the assignment of benefit agreement may be nullified.
Adding to his concern is that many GP-to-practice service agreements contain a clause which states that the responsibility for billing, collection, reconciliation and receipting all fall to the practice entity.
“Pretty much the majority of practices in Australia have these things called service agreements, saying, ‘hey doctor, welcome, we’ll do your billing for you and your appointments for you’, and there’s an inferred responsibility that you’re going to do it properly,” Mr Dahm said.
“Well, what happens if you don’t? Are you negligent? Do I get to sue you for every time you missed the [assignment of benefit]?”
The risk in having even a small portion of assignment of benefit errors, in Mr Dahm’s view, is that the government may find that mistake on an audit and assume it occurred on multiple other occasions.
This is similar to the way a PSR committee will sample a smaller number of records and extrapolate service patterns over an entire year, for example.
Mr Dahm’s prediction is that many clinics will choose to move to private billing in order to minimise their risk of exposure.
Related
It is worth noting, however, that DoHDA has agreed to take a risk-based approach to assignment of benefit non-compliance for the time being.
Basically, it will start with education-only compliance measures in cases where there were honest mistakes.
It has also committed to using the 12-month transition period to “explore other legislative and regulatory options to further reduce administrative burden on practitioners and patients while maintaining the integrity of Medicare”.
“The Government’s intent is that these reforms do not affect patients’ access to timely bulk billed care,” the most recent DoHDA-issued fact sheet reads.
Mr Dahm said he was still hopeful that DoHDA would move to fix the remaining gaps as soon as possible.
