
The billing process for patients with multiple insurance plans can be complex, and it's essential to understand the rules and regulations to ensure accurate and compliant billing practices. When a patient has both commercial insurance and Medicaid coverage, specific guidelines dictate how providers should bill for their services. This scenario raises questions about primary and secondary insurance, coordination of benefits, and adhering to the policies of each insurance type. Understanding these rules is crucial for providers to receive proper reimbursement and protect patients from unexpected financial burdens. In this discussion, we will delve into the intricacies of billing patients with dual insurance coverage, focusing on commercial insurance and Medicaid, to ensure compliance and fair practices for all parties involved.
| Characteristics | Values |
|---|---|
| Can a patient have both commercial insurance and Medicaid? | Yes, a patient can have both. |
| Can a provider bill a beneficiary for services covered by Medicaid? | No, unless there is a prior agreement that the beneficiary is being seen as a private pay patient. |
| Can a provider make a private pay agreement with a beneficiary to accept a Medicaid fee and then provide an upgraded service? | No, this is an unacceptable practice. |
| Can a provider bill a beneficiary after advising them that their Medicaid card is valid? | No, the provider may not change their mind and bill the beneficiary for that service or any part of that service. |
| Can a provider bill Medicaid fee-for-service for any services? | It depends on whether the provider participates in Medicaid fee-for-service and the nature of the service. |
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What You'll Learn

Billing for emergency services
In the United States, emergency medical services (EMS) provide out-of-hospital acute medical care and/or transport to definitive care for those in need. EMS workers face numerous occupational hazards due to frequent changes in their work environment throughout the day. These risks are similar to those faced by other health professionals. EMS delivery in the US can be based on various models, with most services being at least partially publicly funded. Some EMS providers operate on a fee-for-service basis, charging patients directly for emergency services.
In the context of billing, it's important to distinguish between emergency and non-emergency care. The No Surprises Act, which came into effect on January 1, 2022, protects individuals with health insurance from unexpected out-of-network bills for emergency room visits. However, this protection doesn't extend to non-emergency care related to a visit to an in-network facility. In such cases, providers must give patients a good faith estimate of the expected costs if requested or if services are scheduled at least three business days in advance.
When it comes to ambulance services, it's common for individuals to receive surprise out-of-network bills. In about half of ambulance trips, the service is out of network and not covered by insurance. This often results in high out-of-pocket expenses, with median bills around $450 and averages exceeding $1,000 in some states. This issue arises because emergency dispatchers send the closest available medical transport, regardless of whether they are in-network for the patient's insurance.
To address surprise ambulance bills, individuals can take several steps. Eighteen states have enacted protections against such billing, but these typically only apply to state-regulated insurance plans. For those with private employer-sponsored coverage, federal action is needed to extend similar protections. It's recommended that individuals get the emergency care they need and then address the financial aspects afterward. Strategies for managing unexpected ambulance bills include negotiating with the ambulance provider, who may be willing to offer a discount or payment plan, and ensuring that the bill has been processed through insurance, even if out-of-network.
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Billing for long-term care
When it comes to long-term care, billing procedures can be complex and vary depending on the patient's insurance coverage and the specific services provided. Here are some important considerations for billing for long-term care:
Understanding Insurance Coverage: Long-term care can be costly, and patients often rely on a combination of private insurance, Medicare, and Medicaid to cover the expenses. It is essential to verify the patient's insurance coverage and understand the specific benefits and limitations of their policy. Some policies may have a cap on the number of days or the amount covered for long-term care services.
Billing for Nursing Home Care: Nursing homes typically require a responsible party to sign an agreement, making them financially liable for the resident's care. It is crucial to carefully review and understand the terms of the agreement before signing. If the resident has a long-term care (LTC) insurance policy, it is important to inform the nursing home upon admission. Some LTC carriers will pay the nursing home directly, while others may reimburse the policyholder. In the case of Medicaid, some nursing homes may have specific preferences or requirements for billing and reimbursement.
Monthly Billing and Reimbursement: In many cases, long-term care providers are required to submit monthly billing for reimbursement purposes. This process can vary depending on the state and the type of care provided. For example, nursing facilities, including intermediate care facilities and supportive living providers, may have different billing requirements and timelines.
Coordination with Social Services: If a resident's funds are depleted and they are unable to continue making private payments, it is important to contact the county's Department of Social Services. They can provide information and assistance with the Medicaid application process, which can be complex and time-consuming. Some states may have specific requirements and resources to support individuals in this situation.
Skilled Nursing Care and Insurance Coverage: For patients requiring skilled nursing care, it is important to check the terms of their insurance policy. Both Medicare and secondary health insurance policies, such as Medigap, may cover skilled nursing care expenses, but the coverage can vary. Understanding the specific benefits and limitations of the policy is crucial to ensure proper billing and minimize unexpected costs.
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Private pay agreements
For example, if a patient utilises services from UCM Digital Health, they enter into a private pay agreement where they understand that the fees outlined in the agreement do not include prescription medications or other treatments prescribed by the service provider or professionals. The patient agrees to be solely responsible for the payment of such additional costs, understanding that separate bills may be received for these items. Additionally, the patient directs the service provider not to submit any claims to a government program or commercial health plan for reimbursement.
In the context of health insurance, private pay enrollees in the Washington health insurance plan have their premiums paid without relying on state or federal funds. This definition highlights that private pay individuals are those who do not have their payments established by a third party, such as the Veterans Administration or Medicare. It is important to note that private pay individuals must still meet functional eligibility conditions to qualify for certain services or programs.
Overall, private pay agreements outline the financial responsibilities of patients who are paying for healthcare services without utilising public or private health benefits programs. These agreements ensure that patients understand the costs associated with their care and the expectations for payment.
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Billing for family planning services
In Colorado, the Department of Health Care Policy & Financing has expanded family planning and family planning-related health benefits to individuals who would not have been eligible for Health First Colorado (Colorado's Medicaid program). This expansion is based on bills passed in the 2021 and 2023 legislative sessions.
People residing in Colorado who do not meet citizenship requirements but meet all other eligibility criteria for Health First Colorado are now eligible for coverage of family planning services, family planning-related services, and emergency services. This includes individuals without documentation and those with incomes between 133% and 260% of the Federal Poverty Limit (FPL).
Family planning services should be provided by Health First Colorado-enrolled licensed practitioners within the scope of their practice. Claims should have the appropriate CPT/HCPCS codes designated as family planning services with an FP modifier at the detail level. The diagnosis code should indicate that the intent of the visit was for "family planning services."
Health First Colorado members, including those in the EMS and FAMPL benefit plans, are not required to pay a copay for family planning services. Providers may offer services to help members plan for a pregnancy, such as counseling regarding the reproductive system and fertility awareness, and initial evaluations of a member's ability to achieve a healthy term pregnancy.
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Billing disputes and complaints
If you have a billing dispute, the first step is to carefully review the bill and identify any discrepancies or errors. Common issues include duplicate charges, incorrect dates of service, or charges for services not received. You should also be aware of your insurance coverage and the terms of your policy to identify any discrepancies between the billed amounts and your expected coverage.
If you identify a potential issue with your bill, you can reach out to your insurance provider or the healthcare provider's billing department to seek clarification or rectify any errors. It is recommended to keep detailed records of your communications, including dates, names of individuals you spoke with, and the content of the discussion. This information can be crucial if the dispute escalates.
In the case of Medicaid beneficiaries, it is important to understand that providers who accept Medicaid beneficiaries as patients agree to bill Medicaid for the services provided. They cannot charge beneficiaries for services covered by their Medicaid managed care or FHPlus contract unless there is a prior agreement for private pay. If a provider advises a beneficiary that their Medicaid card is valid for a particular service and then treats them, they cannot change their mind and bill the beneficiary for that service afterward.
If you believe that your bill is incorrect or if you have been improperly charged, you have the right to dispute the charges. You can start by contacting the provider and trying to resolve the issue directly. If this is unsuccessful, you can submit a formal complaint to the appropriate authorities, such as the state's Department of Health or the Centers for Medicaid and Medicare Services (CMS). Each state may have specific procedures for handling billing disputes, so it is important to familiarize yourself with the relevant processes in your state.
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Frequently asked questions
No, unless there is a prior agreement that they are being treated as a private pay patient.
The CSC Call Center must be contacted first. If the claim is for a service included in the Medicaid managed care or FHPlus benefit package, the enrollee's managed care plan must then be contacted.
No, a provider may not make a private pay agreement with a beneficiary to accept a Medicaid fee for a particular covered service and then provide an upgraded service, agreeing to charge the beneficiary only the difference in fee.
No, if a provider tells a beneficiary that their card is valid and treats them, they may not then bill the beneficiary for that service or any part of that service.
A provider who participates in Medicaid fee-for-service may not bill Medicaid fee-for-service for any services included in a beneficiary's managed care plan, with the exception of family planning services when not provided under a contract with the recipient's health plan.











































