Understanding Your Responsibility for Fee-for-Service Billing

Fee-for-Service (FFS) billing provides physicians with autonomy and flexibility in how they practice. With that flexibility, however, comes an important responsibility: physicians are ultimately accountable for ensuring that claims submitted under their billing number are accurate, supported by the medical record, and consistent with the services provided. 

Delegating Billing Does Not Transfer Responsibility

Physicians may delegate billing-related tasks to clinic staff, billing companies, clinic owners, or other third-party services. Delegation can be an efficient and appropriate part of running a practice, but it does not transfer responsibility for the claims. 

The physician remains responsible for ensuring that: 

• the tariff billed accurately reflects the service provided; 
• the claim is submitted under the appropriate billing number; 
• the medical record supports the service claimed; 
• applicable billing rules and restrictions are followed; and 
• billing practices are reviewed when questions or uncertainties arise. 

If an issue is identified through a Manitoba Health review or audit, responsibility ultimately rests with the physician whose billing number was used to submit the claim. 

Be Cautious About Word-of-Mouth Billing Advice 

It is natural for physicians to discuss practice and billing issues with colleagues. These conversations can be helpful, but physicians should exercise caution when relying on informal, word-of-mouth billing advice. 

Billing rules can be nuanced, and the appropriate tariff may depend on the specific circumstances of the encounter, the service provided, and the documentation supporting the claim. A billing approach that may be appropriate in one situation or for one physician may not necessarily apply in another. There is also a risk that the advice being shared may itself be based on an incorrect interpretation or an established billing practice that has never been reviewed against the Physician’s Manual.

Following inaccurate or inapplicable advice can result in: 

• claim rejections or adjustments; 
• incorrect or inappropriate billing; 
• Manitoba Health reviews or audits; and 
• potentially significant repayment obligations. 

Ultimately, if a billing practice is found to be incorrect, the physician who submitted the claim remains responsible, even if the practice was recommended by a colleague, biller, clinic manager, or other individual. 

An honest belief that a billing practice was correct does not necessarily establish that the claim was appropriate. Physicians should therefore take reasonable steps to understand and verify their billing practices and, when necessary, seek clarification from an appropriate source before relying on advice. 

Make Billing Accuracy Part of Your Practice

Good billing practices should be approached with the same care and attention given to other professional responsibilities. 

Physicians should regularly review their billing practices, particularly when: 

• introducing a new tariff or service; 
• changing practice models or workflows; 
• receiving advice from colleagues or billing staff; 
• encountering a service that does not clearly fit an existing tariff; or 
• receiving questions or feedback from Manitoba Health. 

When there is uncertainty, the safest approach is to go back to the source. Review the Physician’s Manual and seek appropriate advice rather than relying solely on what another physician, colleague, or biller may have done in the past. 

The Bottom Line

The physician is ultimately responsible for the accuracy of claims submitted under their billing number. Taking the time to understand the applicable rules, verify billing advice, and periodically review billing practices can help reduce errors and ensure that claims accurately reflect the care provided.