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Home Billing Decoded

Patient Financial Responsibility: Rules and Policies for Waiving and Hardships

by Leslie Sisson, CFo, CFm; Curt Bertram, CPO, FAAOP; and Michelle Wullstein, CPCO
June 1, 2025
in Billing Decoded
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What may seem like an act of kindness or generosity, the Office of Inspector General (OIG) considers to be a form of renumeration.

Routinely waiving patient deductibles and coinsurance is a violation of CMS policies and could result in the imposition of civil monetary penalties as it violates both the anti-kickback statute and the beneficiary inducement statute—and because it falls under the anti-kickback statute, it is not limited to CMS claims. We commonly associate kickbacks with physician referrals and inducements; however, a kickback may also apply to patients if suppliers are incentivizing patients for their business.

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