Navigating Dual Fee Schedules in Chiropractic Practices

How to Avoid Risky Chiropractic Billing Practices While Keeping Care Affordable

Key Takeaways

• Dual fee schedules may lead to violations of insurance contracts, audits, or even fraud claims.
• Charging different rates based on how a patient pays can create serious legal and ethical risks.
• You can offer compliant discounts through time-of-service policies, hardship plans, or memberships.
• Clear pricing, consistent documentation, and staff training are key to protecting your practice.
• ChiroSpring helps you manage billing and memberships in one place so you can stay organized and compliant.
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Dual fee schedules can be a legal and ethical minefield for chiropractic practices. Many offer lower rates to cash-paying patients to make care more accessible. But charging different fees for the same service, based on how a patient pays, can create serious compliance concerns.  

Understanding the risks is only step one. Here’s how to protect your practice and make your chiropractic billing work better for everyone.

What Are Dual Fee Schedules?

A dual fee schedule refers to charging different rates for the same service based on how the patient pays. For example, a chiropractor might bill one rate to insurance and offer a lower rate to patients who pay out of pocket.

These fee differences often develop unintentionally. Many practices adopt them to make care more accessible or because it seems like the industry norm. But without a clear, consistent structure, even small price differences can lead to billing inconsistencies and raise questions with insurers.

Understanding how dual fee schedules work—and how they’re viewed by payers and regulators—is the first step to protecting your practice.

Legal Risks of Dual Fee Schedules

When practices use inconsistent fee schedules, it can quickly lead to legal trouble.

Here’s where chiropractors often run into issues:

• Insurance fraud. Billing one amount to insurance and charging a different rate to a cash patient (without proper documentation) can be seen as misrepresentation. ‍
• Anti-kickback concerns. Waiving copays or offering selective discounts in exchange for referrals may violate federal kickback laws. ‍
• Stark Law violations. Tying price differences to referral relationships can raise compliance concerns under Stark Law.

Such violations can lead to audits, fines, or legal action. Even unintentional pricing differences can cause problems if they don’t follow the rules.

How Inconsistent Pricing Leads to Compliance Violations

Most billing violations don’t happen overnight. They build from routine decisions without clear documentation or a written policy in place.

Moreover, inconsistent pricing or missing documentation can have serious consequences. You could face denied claims, lost contracts, or—in some cases—False Claims Act penalties if insurers view it as intentional overbilling.

As of January 2025, FCA penalties now range from $14,308 to $28,619 per violation. It doesn’t take many claims to put your practice at serious financial risk.

This is why consistency, documentation, and a clear fee policy are essential to protecting your practice.

Ethical Concerns in Patient Billing

When patients find out they were charged differently than someone else for the same service, it can feel unfair—even if your intention was to help. That kind of surprise can damage trust, especially in practices where patients are already paying out of pocket.

Patients should understand what they’ll be charged, why that amount applies to them, and whether it changes based on how they pay. In cash-based practices, that transparency can go a long way.

When your billing is fair and predictable, you’ll build confidence in both your care and your professionalism.

Compliant Alternatives to Dual Fee Schedules

There are ways to give patients more flexibility without putting your billing at risk. But they only work if you’re consistent, have clear policies in place, and use systems that help you stay organized.

Time-of-Service Discounts

TOS discounts are legal in many states, but they have to be applied carefully to stay compliant. Here's how to do it right:

• Use a written policy. Don’t apply discounts ad hoc. ‍
• Be consistent. Offer the same discount to all who qualify. ‍
• Keep it modest. The discount should reflect cost savings, like avoiding claim filing. ‍
• Stay within contract limits. Don’t discount below your lowest contracted insurance rate. ‍
• Document it. Note the discount clearly in the patient’s record and billing system.

Discount Medical Plan Organizations (DMPOs)

DMPOs let you legally offer discounted rates without violating insurance contracts. Patients pay a small membership fee to join the network and access reduced service fees at your practice.

To use them correctly:

• Join a legally recognized DMPO. Make sure it’s approved in your state. ‍
• Apply rates consistently. All DMPO members should receive the same pricing. ‍
• Document each visit. Keep a clear record whenever the discount is used.

ChiroSpring Billing & Memberships

Membership plans are one of the simplest ways to offer affordable care without creating compliance problems. When handled through your software, it’s easier to keep pricing consistent and properly documented.

ChiroSpring brings billing and membership tools into one system. It helps your team apply pricing consistently, track payments accurately, and keep patient plans organized from start to finish.

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Best Practices for Fee Transparency  

You can have the right strategies and systems in place, but if your fee structure isn’t clear, it’s easy to apply things inconsistently or confuse patients.

Use these steps to keep your pricing clear, consistent, and easy for both patients and staff to follow:

• Stick to one fee schedule. Avoid separate pricing for different patient types. ‍
• Include fees in intake paperwork. Patients should see what things cost before their first visit. ‍
• Post your rates somewhere visible. A printed sheet at the front desk works fine. ‍
• Train your team. Staff should be able to explain fees clearly and answer common questions. ‍
• Avoid making exceptions. One-off discounts or case-by-case pricing cause confusion and risk.

Clear pricing makes it easier to have honest conversations and fewer billing surprises.

Set Your Chiropractic Billing on the Right Track

Patient billing shouldn't put your practice at risk. But without clear policies, consistent fees, and a plan for handling discounts, small decisions can lead to serious problems. Most chiropractors are doing their best to keep care accessible, not trying to bend the rules. Still, the risk of compliance issues is real.

You don’t have to figure it all out on your own. From creating membership plans to applying discounts the right way, ChiroSpring helps you keep pricing consistent, billing accurate, and documentation clean. It’s built for chiropractors and makes the business side of care easier to manage.

Stop worrying about how you charge.
Start feeling confident in the way you run your practice.

Schedule your ChiroSpring demo today.

FAQs About Chiropractic Billing Compliance

What constitutes a dual fee schedule in chiropractic practices?
It means charging different prices for the same service depending on how the patient pays, such as billing insurance one rate and offering a lower cash rate.

Why are dual fee schedules problematic?
They can violate provider agreements, lead to audits, or even result in fraud allegations if they’re not handled correctly.

How can I offer discounts without using a dual fee schedule?
You can use time-of-service discounts, financial hardship policies, or membership plans. The key is to apply them consistently and document them clearly.

What is a DMPO, and how does it work?
A DMPO is a membership-based network that lets you offer reduced service rates legally. Patients pay to join the plan and get access to those rates under a set structure.

How can ChiroSpring help ensure billing compliance?
It gives you tools to apply pricing consistently, automate billing, and manage membership plans in one system. That makes it easier to stay organized and avoid common compliance risks.  

References

Chiropractors, Dual-Fee Schedule Chiropractic, and the Future of Direct Pay Healthcare. (n.d.). Patient Options. Retrieved April 16, 2025, from https://patientoptions.org/chiropractors-dual-fee-schedules-and-the-future-of-direct-pay-healthcare/

How to Charge Your Patients in a Chiropractic Cash Practice. (2025, February 1). Chirospring. https://www.chirospring.com/articles/how-to-charge-patients-in-a-chiropractic-cash-practice

Stein, S. D. (2025, January 6). 2025 Inflationary Adjustments to FCA Penalties Announced. False Claims Act Blog; Sidley. https://fcablog.sidley.com/2025/01/06/2025-inflationary-adjustments-to-fca-penalties-announced/