When, (not if) caught, Miss Moneypenny of the Medical Funding industry, will want every cent back, and more. Some of you will face massive clawbacks from the funders, and all those who are found to have participated will end up at the HPCSA, where up to 3 years of misery awaits.
As Dr NO in the Bond Movies says: “What is it about "NO", that is hard to understand?”.
So before you quaff your final martini of the year, be sure that YOU are not “shaken, not stirred” by the SIDs, the Hawks, or the Fraud units of the various funder groupings
The following perennial questions have again arisen and whether these imaginative and innovative accounting entities are permissible or not has been investigated time after time, and have been found to be a resounding “NO”.
- Are you permitted to charge the patients a fee for "Administration", or submission of an account through your switch on behalf of the patient, or for submitting proof of a paid account to the funders for refund to the patient?
- Can you charge your patient a fee to post their account to the funder?
- Can you charge for performing an uncomplicated PAP smear?
- Can you charge a member a co pay after having signed into a DSP arrangement with that patients medical aid, in which you agree not to do so?
- Can you "hire out" portions of your waiting room to companies to install TV sets to advertise products and play patient informationals?
- Can you receive payment from a pharmaco to" rent out shelf space" in your dispensary to house consignment stocks of medicines?
- Can you receive payments (cash or other incentives) from wholesalers, or other sources, as a sweetener to place your order with them?
- Should you be paid data fees, based upon information gleaned from your patients, for any reason?
- Can you charge pathology codes for quantitative tests, when you only perform semi quantitative test procedures?
- Can you charge your patient one fee, and then provide him with a receipt for a different, lesser amount to claim back from his medical aid funder?
- Can you charge an after-hours fee when you run an emergency unit which is, in any event open 24/7?
- Can you charge an after-hours fee if you elect to open after hours and have open hours advertised to the public?
- Can you charge for issuing a sick certificate?
- Can you charge for, or even be paid separately by a third party for issuing a prescription, when it is part of the consultation?
- Can you be paid extra for any part of a consultation, in return for permitting your data to be sold?
- Can you charge for one service, but perform another different service? (excepting when you legitimately use General rule C).
- Can you charge a medical aid funder for one patient when you know that the patient is not a registered dependent, and therefore you charge the cost to a duly registered members with their acquiescence?
- Can you offer to see an unregistered patient and agree to charge your service to a funder, in the name of a registered dependent?
- Can you provide money to the patient in return for the patient permitting you to bill their funder for services which you have not rendered?
- Can you sell non pharmaceutical goods to your patients or to the general public?
- Can you allow non-medical persons to operate your practice and generate you or accounts without your direct supervision?
- Can you work for a practice owner who is not a doctor?
- Can you receive a percentage of your turnover as your income, if you are a locus or an assistant?
- Can you permit your payments from a funder to be paid into the account of a non-medical person instead of into your practice account, and then be paid a portion of the amount received, and leave the balance with the entrepreneur?
- Can you share premises or an entrance with a pharmacist?
Don’t wait for the Man with the Golden Gun, to arrest you!
Don’t wait for the Sky to Fall.
Don’t wait for your career to end in a Thunderball!
Don't wait until the HPCSA sends in search party with a warrant to impound your computer as their Dr NO, announces himself, with the proverbial:
“Good evening ….Mr Bond"
JUST DON’T DO IT!!!!
Tony Behrman and the IPAF Team