Perhaps it's worth thinking more broadly about “uninsured services”? Services paid for by the AHCIP (e.g. listed in the SOMB) are called "insured services”. But AHCIP isn’t insurance in the usual sense - funding by provincial/federal taxes isn’t the same as premiums, AHCIP doesn't adjust for risk, there are no deductibles or copayments, etc. The key is really that these physician services have been deemed "medically necessary" at some point (or at least, included in the SOMB), and therefore payed for by government. But the Alberta government also pays for physician services via ARPs, the new PCPCM for primary care docs (which includes time spent on "indirect patient care" and "practice management"), and other payment mechanisms. How do these services fit into the definitions of “insured” vs “uninsured” services?
Docs are also payed via truly insurance-like structures (e.g. WCB), and by a whole raft of third-party payers (e.g. AISH, insurance companies, employers). CPSA-regulated members can also opt-out of AHCIP altogether, and be paid *only* by patients, commercial ("private") health insurance, "executive benefits" programs, etc. It’s worth thinking about Alberta docs who opt out of AHCIP (same for those rare Alberta patients who opt-out), as it’s a blind spot in this Standard. What I’m getting at is that the Standard should probably be “Charging Patients for Professional Services” rather than “Block Fees & Charging for Uninsured Professional Services”?
Speaking of insurance - block fees are essentially healthcare insurance SOLD BY PHYSICIANS for services not paid by AHCIP. Pts pay a fixed amount (i.e. premium), hoping they'll come out ahead compared to paying individual service fees (i.e. deductibles). And docs get their block fee/“premium” up front, so they're not chasing pts for fees at-time-of-service.
I think adding the line “Uninsured professional services do not include the costs of maintaining an office, maintaining medical records or arranging appropriate medical referrals” opens a can of worms:
- some docs must pay “the costs of maintaining an office, maintaining medical records”, etc, and some docs don’t pay these costs because AHS pays them
- if we’re assuming that AHCIP fees should include an amount to cover overhead costs, then presumably a fee charged to a patient should also include overhead costs, even if not itemized as such?
- calling out “arranging appropriate medical referrals” (what about surgical referrals?!) doesn’t make much sense, relative to all the other things docs do for patients. And definitely scrap “appropriate” - unless patients should be charged for inappropriate referrals?
- this line contradicts paragraph 3, if “administrative costs” is read to mean overhead.
The definition of “Insured services” is problematic, as “medically required” is too open to interpretation - it should really just mean “what AHCIP pays for, as defined in the SOMB”. But again, what about ARPs, the PCPCM, and other government-funded physician payment structures?
I personally agree with the section on block fees, which effectively treats these as optional “fees paid as a block”, rather than the way they’ve started to become used to skirt the differentiation of public from private payment for clinic services. Raising the bar, for those using this tool, will help keep this in check. I particularly like the items around transparency for patients. If we docs were on the other side of the counter, being offered a “block fee” option by our own doctor, I think these are the guardrails we’d appreciate having.
For missed appointments, paragraph 12.d - “ensure charges reasonably reflect the actual costs incurred” - is tricky. Many clinics currently use escalating charges, as an attempt to modify patient behaviour around missed appointments, but not rationalized around “costs incurred”. For that matter, there are no costs incurred specifically by missed appointments, only revenue not gained - perhaps “ensure charges reasonably reflect lost revenue” would be better? Many clinics also leverage inability to book further appointments until missed visit charges are paid, also to attempt behaviour change. Personally, I think the underlying reasons most patients miss (or recurrently miss) appointments are only counterbalanced by these tools for a small subset of patients, while causing significant harm to the majority of patients for whom they are not effective countermeasures, so I’m in favour of rationalizing the handling of missed appointments around missed revenue rather than behaviour modification tools. However, to fill the void in how clinics manage missed appointments, it would be very helpful if the CPSA could develop resources on more effective tools clinics can use for this.




















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