REP 15 - Good practice: fees and fee guidelines
Physiotherapy Alberta is contacted on a regular basis by both members and the public who want to obtain a copy of the fee schedule or guideline.
In fact, no such guideline exists.
The last version of such a document was released by the Alberta Physiotherapy Association (APA) in 2009.1
It should be noted that although many perceived otherwise, all fee guidelines published by the APA were non-binding and business owners were always free to adjust their fees based upon their own costs.2
Since 2009, Physiotherapy Alberta has chosen to direct members to set their own fees based upon their business model, the services they offer, their costs to provide those services and what the market will bear.
This reflects a philosophical belief that physiotherapist business owners are best able to determine appropriate fees based on their overhead, as well as a lack of jurisdiction to regulate fees.2
In the past, the Competition Bureau has indicated some concern regarding the practice of professional associations establishing fee guidelines for their members, as it may impede fair competition within the market place.3
Barring a hard and fast fee guideline, members need to remember that the Fees and Billing Standard of Practice,4 provides direction regarding appropriate fee setting practices. Some concerns that are frequently brought to my attention as Practice Support Advisor or Physiotherapy Alberta’s Complaints Director include the following:
- Fees for chart copies
- Transparency of fees and billing practices
- Bundling fees or offering special deals
- How to sign receipts
- How to bill for services provided by support workers
The Standard of Practice is quite explicit in requiring members to be transparent in their billing practices. Patients should be aware of the fees for services and practices regarding billing for missed appointments from the outset of treatment.4
It is equally important that these fee guidelines be applied consistently and fairly. If the clinic says it charges for missed appointments, it needs to do so every time. If the policy is that patients get “one free miss” before being charged, then all patients must get that same treatment.
Prior to providing reports or chart copies to patients or third-party payers, physiotherapists are required by both the Standards of Practice and by privacy legislation to provide an estimate of the charges to the requesting party.4,5,6
There are also clear legislated limits set out in the Health Information Act (HIA) which stipulate the acceptable charges for chart copies for patients seen in public settings or under the Diagnostic and Treatment Protocols Regulation (DTPR).5
Although the privacy legislation regarding chart copies for non-DTPR (private practice) clients is less prescriptive,6 the Office of the Privacy and Information Commission has provided an opinion on what they would consider a reasonable fee for chart copies, and is quite similar to the fees stipulated by HIA.7
Clinicians must make themselves aware of legislation that stipulates fees and ensure that they are in compliance. Where fees are not stipulated, members are encouraged to reflect on what a reasonable fee is for access to information, keeping in mind that the information in question clearly belongs to the patient.
Does what you are charging pass the “mother test?” What would you consider to be a reasonable fee for your family member to pay for a copy of their chart?
The Standard of Practice for Advertising and Promotional Activities8 clearly states that at no time should a physiotherapist promote unnecessary services and also bans the use of time-limited pricing, discount coupons or package deals for the very fact that these mechanisms tend to promote such unnecessary service.
Billing for Services Provided by a Support Worker
When it comes to billing for services provided by an assistant, it is our position that the physiotherapist needs to oversee the service delivery and have assigned specific tasks to the assistant.
In other words, if you want to call it physiotherapy, the service needs to be directed, supervised and provided by a physiotherapist. Billing for physiotherapy services provided in their entirety by an assistant in the absence of a physiotherapist is inherently unethical.
How to Sign Receipts
When it comes to issuing receipts, it should be noted that Physiotherapy Alberta provides members with registration numbers. These are not, from our perspective, “billing numbers.”
Clinicians tend to provide receipts with their registration numbers so insurers can verify that the member is registered to practice in Alberta. It is common that insurers will not reimburse for physiotherapy services provided by those who are not registered.
Allowing someone else to use your registration number for billing purposes is equal to allowing someone to use your identity.
Determining how to set fees that are fair and allow a business to earn a profit and how to assess if a contract is lucrative are challenging questions. In the end, having fees that are clear, consistent and transparent and that are charged in exchange for high-quality patient service is at the heart of good practice.
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