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The SPA Code of Ethics (2010) includes the principles of
Truth and Professional Integrity, among others, which are to be
applied to all of our professional behaviour. These principles
are applicable to many areas of speech pathology practice,
including utilising appropriate and legal business practices
when invoicing for our services.
It is the responsibility of speech pathologists to ensure
that invoicing complies with federal (and state) laws, which
include the rules regarding billing under the Medicare Benefits
Schedule (MBS). Most speech pathologists working in private
practice are aware of the four MBS programs that provide
rebates for speech pathology services provided to clients with
specific diagnoses or conditions: Helping Children with Autism
Programmme, Better Start for Children with Disability initiative,
Chronic Disease Management Programme, Follow-up Allied
Health services for people of Aboriginal or Torres Strait Islander
descent.
Information about the programs can be found on the Australian
Government Department of Health website, and MBS online
.
Each program has specific rules regarding eligibility for both
the speech pathologist and the client, the number and type of
sessions that can attract a rebate, item numbers and reporting
requirements. The SPA information sheet has more information:
Medicare Programs and Provider Numbers, plus specific FAQ
sheets on the Medicare programs.
Speech pathologists must be registered with Medicare to be
eligible to provide rebatable speech pathology services, as
well as being a current, financial practising member of Speech
Pathology Australia at the time the rebatable service was
provided. Medicare conducts an audit of speech pathologists
with Medicare provider numbers early each year. During this
audit they check whether each speech pathologist with a
Medicare provider number has renewed their SPA membership
by the due date (1 January) and whether they have renewed
as a practising member. Periodically, Medicare may conduct
audits of service and claim transactions.
To ensure your invoicing is appropriate here are a few do’s and
don’ts:
• Ensure the dates on your invoices are accurate, i.e. the
service must have been provided on the date specified on
the invoice.
• Do not record a different date. If you had not yet renewed
your SPA membership when you provided the service,
your client cannot claim the MBS rebate for that date.
• Do not pre-invoice remaining sessions for a child utilising
HCWA funding to ‘use up’ the funding prior to their
seventh birthday, with the intention to then provide those
sessions after the child’s birthday.
• Only invoice for sessions attracting a CDM rebate that you
have actually provided.
• Any of the above actions may be considered fraudulent,
and will be identified in a Medicare audit.
Further information regarding Medicare programs can be found
on the resource for members tab, under the
Medicare section, or you can contact:
Nichola Harris, Practice and Clinical Support Advisor, advisor@
or
Trish Johnson, Senior Advisor Ethics and Professional Issues,
If you have professional indemnity insurance with Guild then
you can also call their duty lawyers for advice.
Ethics: The do's and don'ts of
appropriate invoicing
Trish Johnson
Senior Advisor Ethics and Professional Issues
It is the responsibility
of speech pathologists
to ensure that invoicing
complies with federal
(and state) laws.
ethics news