Confidentiality, Privacy and Security

Credit Card Charge Dispute and ROI

  • 1.  Credit Card Charge Dispute and ROI

    Posted 06-05-2019 16:42
    The provider pertaining to this question is a psychologist. Prior to treatment (along with a myriad of other forms) we provide an estimate of the patient's out-of-pocket costs and clearly state that this amount is an estimate only, and that the actual amount owed will be determined once the claim has been processed by the insurance company. They sign a (lawyer-created) form authorizing us to charge their method of payment for any balance related to treatment and provide us with their credit/debit or ACH information.

    The patient receives the same EOB that we receive and, of course, this lists his/her financial liability. Once we receive the EOB, we charge the card.

    A patient just disputed a charge as fraudulent and we must dispute the charge-back by June 10th. My proof would be the form signed by the patient, authorizing the use of their card for services provided by us, and the EOB that states the services rendered and the member responsibility.

    My question:
    This information would be shared in an effort to receive payment for services that the patient received in our office, so would releasing this information be permitted under HIPAA?

    Thank you for any advice.

    Jennifer Ziegler, CMRS, CPCO
    Velocity Medical Billing LLC

  • 2.  RE: Credit Card Charge Dispute and ROI

    Posted 06-06-2019 11:33

    Wow, what a great case study.


    I am no JD, but my initial thought would be that since the patient initiated the disputed claim, they are giving permission for you to provide documents to support your response to the CC company.  It should be reasonably expected.


    I assume the only document needed would be the signed authorization to use the card.  You wouldn't be supplying treatment records, just business records.  Perhaps an addendum be added to the current authorization that states, that in the case of disputed claims, you will be supplying the CC company the signed authorization as proof...or something like that to cover you for releasing that document.  And/or it should be added to the NPP if it is not covered already. 


    I am interested in hearing how this turns out and other's opinions because this would make a great case study for students.




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  • 3.  RE: Credit Card Charge Dispute and ROI

    Posted 06-07-2019 08:40
    I think you could make a very strong case that this is a "payment" activity.

    Nancy Davis, MS, RHIA, CHPS
    Director of Compliance & Safety
    Door County Medical Center