Does “Direct One-on-One Patient Contact” Apply to Commercial Insurers?

I receive many questions at my in-person seminars and via email that begin something like “I know we can’t have 2 Medicare patients being treated at the same time, but how about 2 patient’s with commercial insurance”? Or, “I know I need to be one-on-one with Medicare patient’s, but that does not apply to patients with commercial insurance, right”? Lastly, “I know if I have 2 Medicare patient’s in my facility for one hour during the same time period, I have to split the time between them, but if the 2 patient’s had commercial insurance, I could bill each for the entire one hour as one-on-one time, correct”?

I think it is finally time to answer the above questions. Where the answer comes from will surprise many of you. The answer does not come from the Medicare program, commercial insurance carriers, workers compensation programs, auto no-fault insurance carriers or state practice acts and administrative rules. It comes from the