Did you know that CRPO registrants must mark invoices and receipts for missed sessions accordingly? This issue came up in a recent Advocacy Committee meeting, where a member asked that the OSRP highlight this in our newsletter, since it’s not always emphasized by educational programs.

The CRPO standard re: Issuing Accurate Documents indicates that it is not appropriate to issue an invoice for services not provided, EXCEPT when it is clearly reflecting an established fee for a cancelled appointment (e.g., a cancellation fee). What does this mean for you?

If you have an established cancellation policy to which your client has provided informed consent, for example that you charge the full fee without 24 hours notice of a cancellation and/or rescheduling, you can provide a receipt for that payment, but you must indicate that it’s a fee for a session that didn’t happen. 

Why? Most insurers will not reimburse for a missed session. So, if you provide a receipt for the cancellation fee paid to you, but you don’t indicate that this fee is for a session cancelled and/or rescheduled and paid according to your policy, the client could inadvertently submit it to their benefits plan and be fraudulently reimbursed, based on false information you provided.

Even clients without a benefits plan, or without coverage through a spouse or parent, may submit their receipts with their taxes as “Uninsured Medical Expenses,” so the documentation must be accurate.

Some clients can become (understandably) upset to discover that you need to mark the cancellation fee as such rather than as a fee for a session that was actually delivered, since this means they will be paying out of pocket. You really don’t want this to come as a surprise to a client, as it could affect the therapeutic alliance or cause a termination of services if it comes out of the blue.

This is why it is crucial to be clear and upfront, ideally in writing and verbally, about not only your cancellation/rescheduling policy, but how you will need to provide accurate receipts. Making sure your clients understand your policy before proceeding is essential; don’t assume prior knowledge of your business practices.

If you work at a clinic or for another provider, it’s important to make sure their invoice/receipt policy follows this standard, and that you inform your clients in advance of any policies related to cancellation/rescheduling fees and how such fees will be documented. Even if you don’t personally create or issue the invoice or receipt, you are responsible for its accuracy.

The CRPO asks registrants to demonstrate this standard, standard 5.2, by:

• “exercising care to ensure the accuracy of information presented in documents prepared for their signature and transmittal. This includes documents they themselves prepare, and those prepared by others;
• considering how the reader will interpret the information upon receipt and using clear language that cannot be misconstrued;
• not signing or sending documents containing misleading or false information;
• issuing invoices, bills and receipts that are accurate. This includes listing the correct fee, date and time of services provided.”