What Dentists Need To Know About Surcharges For Personal Protective Equipment

Jordan Uditsky • July 30, 2020
When dental practices reopened their doors and resumed seeing patients, they did so in a world that, for all of its familiarity, remains dramatically different than it did before the pandemic consumed American life. Among the myriad new issues that practices needed to confront was the imperative of ensuring the health and safety of their patients and staff. But doing so requires more than modified protocols and procedures. It involves a significant investment in the resources necessary for infection prevention and control, including personal protective equipment (PPE).

While dentists and technicians already incurred significant costs in safety gear pre-pandemic, it is estimated that PPE costs for dental practices are now ten to thirty times higher than they were a few short (or long) months ago. This compounds the challenges faced by practices already reeling from an extended period of lost revenues.

To deal with these additional costs, many dental practices are adopting an approach taken by other businesses such as restaurants and salons by charging surcharges for the costs of PPE. While there is nothing inherently problematic in such charges, which can range from $10 to $40, the way practices notify patients about them and how they seek reimbursement from insurance carriers can raise some tricky issues.

The ADA’s Guidance on Documenting Surcharges

The American Dental Association (ADA) has firmly supported the decisions of practices to impose a surcharge for PPE if they so choose, though it does not provide fee guidance. The ADA recommends that those practices that do impose a surcharge do so transparently and consistently: “It is always best to inform patients of any additional charges to avoid any surprise bills. Providing a documented financial policy and seeking consent is desirable.”

As to how best to document charges related to PPE, the ADA advises dentists to develop a standard office policy to document the specific PPE that will be used across all patients. Alternatively, the ADA recommends that dentists add a note in the patient’s record to document the details of the PPE uniquely necessary for the visit when charging different fees based on the level of PPE used.

Coding, Billing, and Reimbursement

In its April 2020 Statement on Third Party Payer Reimbursement for PPE, the ADA urged third-party benefit programs to either:

• Adjust the maximum allowable fees for all procedures, or
• Allow a standard fee per date of service per patient to accommodate the rising costs of PPE. 

Prior to such adjustments taking effect, the ADA suggests that dental offices use CDT code “D1999 - unspecified preventive procedure, by report” to document and report the use and costs for additional PPE. 

The ADA has also issued extensive guidance for third-party PPE coding and billing. The guidance includes a regularly updated list and outline of the specific policies that various carriers have announced. 

Renegotiating Fee Schedules

The additional costs of practicing during the pandemic era and the need to cover those expenses in ways that minimize the amount passed on to patients may require practices to renegotiate their fee schedules with the dental benefit plans for which they are a participating provider.

Before attempting to renegotiate with a carrier, practice owners should be familiar with and have at the ready a range of facts and figures about their practice they can use to make their case for an adjustment. Regarding coronavirus and PPE-related charges specifically, you should know the added per-patient expense you incur for those expenses. You can break these costs down into added disposable PPE costs per patient, as well as added per-patient estimates to recover engineering controls.

Experienced Dental Practice Counsel During An Unprecedented Time

These are indeed unprecedented times for dentists and dental practices. The challenges of maintaining a viable practice while also bearing the new costs required to ensure patient and staff safety can be overwhelming. That is why it is so critical for dental practice owners to have the business and legal resources they need to help them navigate the uncharted waters of this new era. 

At Grogan, Hesse & Uditsky, P.C., we focus a substantial part of our practice on providing exceptional legal services for dentists and dental practices, as well as for orthodontists, periodontists, endodontists, pediatric dentists, and oral surgeons. We understand the concerns and complexities faced by owners and practitioners as the pandemic remains a dominating presence in their practices. We welcome the opportunity to assist you during these unique and difficult times. 

Please call us at (630) 833-5533 or contact us online to arrange for your free initial consultation.

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