The Institute for Integrative Medicine
6920 Miramar Road, Suite 301
San Diego, CA 9212
Phone: (888) 443-4611 Ext. 710
Copyright © 2013 Institute for Integrative Medicine, All Rights Reserved
The delivery of integrative, holistic, or alternative medicine (sometimes referred to as "Complimentary Alternative Medicine or "CAM") may unintentionally include the delivery of services covered by health care plans (notably, by Medicare due to the age or condition of patients triggering coverage). Since CAM practices are largely cash or private fee practices, practitioners must cautiously and carefully ensure that their services do not collect patient payments for what Medicare covers. With the Accountable Care Act being implemented on a national level, more preventative health care services are now covered by Medicare. Coverage of certain preventative care services is now enhanced or expanded. Care must be taken, therefore, since some CAM services delivered by practitioners may constitute preventative medical services mandated as covered by Medicare with no co-pay or deductible owed. HMO plans prohibit the delivery of medical services covered by the plan for patient compensation in excess of plan reimbursement, and require advance patient consent for voluntary non-medical amenities triggering additional patient payment obligations. Additionally, HIPAA/HITECH implements important patient privacy protections and may be triggered by the storage or handling of any electronic patient information. Federal law mandates patients have access to electronic health records, therefore, care must be taken to avoid charging fees for electronic health records access that is mandated by federal law, or for charges in excess of federal guidelines. Various states often have privacy and medical records access laws similar to federal laws. CAM practices often, but not always, engage in electronic communication with patients and involve family members or significant others with CAM consultations, so care must be taken regarding HIPAA/HITECH compliance with respect to privacy and records access. HIPAA/HITECH requires separate personal health information (PHI) written consent by patients, along with updated notices of privacy practices (NPPs) toward HIPAA/HITECH compliance. Due to the complexities of reimbursement and privacy laws, CAM practitioners are strongly advised to seek competent legal counsel to achieve compliance, and should not rely on IFIM presentations. Materials and information presented by IFIM are necessarily general, non-specific, and do not constitute or replace legal advice. The IFIM specifically disclaims that it is providing legal compliance guidelines, representations, warranties or assurances.