Healthcare Law Briefs

April 2, 2004

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Concierge Medicine:  OIG Says No Tipping

Concierge Medicine has been a hot idea lately; it is defined as an arrangement in which physicians restrict their medical practices, or at least reserve time for a select group of patients, and charge those patients an annual retainer fee for enhanced services, e.g. drop-in appointments, house calls, unlimited phone consultations, etc.  In its original form, physicians would terminate their participation in Medicare and simply serve a self-pay patient base.  The patients themselves, whether they were Medicare beneficiaries or had commercial coverage, might have been able to attain reimbursement from their insurance carrier for some of the services, but the carriers did not pay the physicians directly on an assignment basis. 

One new alternative structure is to continue participation in Medicare, but design the "Concierge" aspect of the practice to cover services which would not otherwise be Medicare covered services.  Since physicians participating in Medicare are prohibited from billing patients directly or additionally for services covered by Medicare, there is an obvious tension in that arrangement. 

OIG issued a press release on March 31^st warning physicians that Concierge arrangements which include Medicare covered services are prohibited by law.  The link to the press release is below.  If you have any questions, please contact Mike Cassidy at mcassidy@tuckerlaw.com.

To download, please click the icon below.)

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>For more information about the topics presented in this newsletter please contact one of the Healthcare Attorneys:

• Michael A. Cassidy

• Richard W. Cramer

• J. Kent Culley

• William T. Harvey

• Michelle L. Kopnski

• Scott R. Leah

• Charles J. Vater

Read the December 2003 issue of our HEALTHCARE NEWSLETTER.

Tucker Arensberg, P.C.

1500 One PPG Place  Pittsburgh, PA 15222   412/566-1212

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