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This consultation ended 20 October 2017



​​​Consultation Notice: Statement on Third-Party Billing

Posted 18 July 2017

The Board of the College of Dental Surgeons of BC (CDSBC) has approved a draft position statement on third-party billing for public consultation.

The statement was developed by the Ethics Committee in response to concerns that some patients, whose treatment involves dental laboratory work that is legitimately performed by a dental laboratory, are subsequently being billed by an intermediate company that operates as a third party. These third parties are interposed between the dentist who ordered the work and the laboratory that provided the laboratory work. They may be owned by or affiliated with the dentist who ordered the work, and may perform inspection and repackaging of product, in addition to the dispatch and receipt of product – procedures that are already part of the work performed by the dental practitioner and their staff or by the commercial dental laboratory. This activity is referred to here as "third-party billing."

If approved, the draft statement will be incorporated into the College's standards and guidelines for registrants.

Draft position statement

It has been brought to the attention of the Ethics Committee that dentists may be using an affiliated or related third party (that itself does not fabricate or provide dental laboratory work) as an intermediary that increases the actual lab fee to be passed on to the patient/payer.

The Ethics Committee is of the view that existing College documents dealing with ethics and patient-centred care confirm this is not appropriate.

The College's standard and guideline document, Patient-Centered Care and the Business of Dentistry, states under Dentist Obligations and Responsibilities, Number 1, that advice offered and treatment provided must be based on the needs of the patient, independent of the business interests of the dentist. The referral to a specific dental laboratory or other third party entity must be based on which lab or third party entity can best provide the necessary service to the patient.

Dentist Obligations and Responsibilities, Number 4, of the same document, states that dentists must treat colleagues and patients fairly in all financial dealings. Charging inflated or hidden fees to increase the amounts dentists receive constitutes unfair treatment to patients, third party payers and colleagues.

The Ethics Committee considered the above mentioned situation and, taking into account the existing College documents, has determined that it is inappropriate for a dentist to increase third party fees charged to the patient/payer beyond the fees paid by the dentist for goods and/or services as billed by the third party who provided them.

The Ethics Committee intends to recommend to the Board that the final version of this statement would also apply to business entities owned by, or affiliated with, a dentist.

Background

The College was asked to investigate a complaint regarding dental laboratory fees that had ethical considerations. The complaint involved a dentist who owned a lab that repackaged lab work provided by other labs, and added an additional fee. The Inquiry Committee asked the Board for direction, which in turn directed the Ethics Committee to consider a framework for dental lab fees. After much discussion and consideration, the Ethics Committee put forward the third-party billing position statement which was approved at the June 2017 Board meeting.

Rationale

CDSBC recognizes that the relationship between patient and dentist differs from that of a business relationship. Because dentists have technical expertise and access to information that patients do not, patients must be able to trust that the dentist is acting in the patient's best interest at all times. This expectation is already spelled out in CDSBC's Code of Ethics (PDF) and in the Standards & Guidelines document Patient-Centred Care and the Business of Dentistry (PDF).

In the case of third-party goods and/or services, where the dentist has prescribed the treatment and undertaken to obtain the necessary third-party goods and/or services, the dentist must act honourably and cannot arbitrarily increase the cost of provided services.

How to submit feedback

Please submit your comment by email or mail no later than 20 October 2017.

By email

consultation@cdsbc.org       

Include "Third-party billing" in the subject line 

By mail

Registrar's Office
College of Dental Surgeons of BC
500 – 1765 West 8th Avenue
Vancouver B.C.  V6J 5C6

Re: Third-party billing

Next steps

This invitation to comment is open to members of the public, dental insurance companies, other dental regulators, UBC Dentistry, CDSBC's partner organizations, other dental professionals and registrants of CDSBC. All comments received by 20 October 2017 will be considered by the Ethics Committee in preparing a final version of the statement for approval by the Board.

The consultation notice for policy items other than bylaws is normally two months. Recognizing that this consultation notice period begins in the summer, we are extending the notice period to three months as a courtesy to all stakeholders.

The principles contained in the final version will then be incorporated in the Standards & Guidelines series for CDSBC registrants.