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Welcome to Pacific Benefit
Consultants, Inc. Cafeteria Plan
Bulletin
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Concierge Services and other
Physician Fees: A Gray Area.
Question: A common question that is being
asked more often goes something like this: My doctor
has started charging patients a monthly fee that is
payable whether or not the patients visit the
office-there is no additional charge for actual
office visits. Is this covered through the Cafeteria
Plan?
Answer: Generally, fees of this type
are not reimbursable. They are generally viewed like
insurance because they are payable whether or not
medical care is provided. Thus, they fall under the
"no reimbursement of insurance premiums" rule that
applies to Health FSAs (not to be confused with
reimbursing individually health policy premiums
under a separate reimbursement account that is not
part of the Health Care Expense Account).
Another variation on this type of fee is the "deluxe
treatment program," under which patients receive
preferential "fringes" from their doctors in
exchange for a fee (e.g., priority when scheduling
appointments, a monthly newsletter, a special
waiting room, etc.). In addition to being insurance
premiums some of these programs would also not
qualify as "medical care".
Note that there could be variations on
these access fee arrangements under which some
services might be reimbursable, depending on how the
program is structured (for example, a fee might
include payments that can be separately allocated to
services that are for medical care). Employees
should not put too much stock in the particular name
given to the fee (retainer fee, concierge fee,
etc.). These terms may mean different things for
different providers. Consequently, it is important
to determine exactly what services are involved
before deciding whether to sign up for this type of
plan- any employee contemplating this type of
program should investigate fully before making a
plan election for the new plan year.
Our
Approach: If in doubt, the conservative approach
would be to not place this type of program through
the Company's Cafeteria Plan. Better for the
employee to be disappointed up front rather than
having these claims denied during the plan year. | |
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FYI Corner: Did you know?
Pacific Benefits has
been administering HSAs for our clients
since HSAs were first introduced.
Our partnership with
my HSA Today, one of the largest HSA
providers in the country, brings all the
technology plus our personal brand of service to your
employees. For more information contact one of our
"Team HSA" administrator/consultants below:
1-800-800-2090
Barb Rainone, ext. 247;
Pam Criswell, ext. 232;
Mimi Silvestre, ext, 226;
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