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Issue #2 • February 2026

The Fee Schedule Shell Game

How carriers claim fee schedules have changed to systematically underpay your claims without formal denials.

This Week's Key Stat
5-15%

systematic underpayment from carriers claiming outdated fee schedules, even when they've agreed to your current rates.

The Carrier Tactic: The Shell Game

Carriers play a sophisticated game with fee schedules. They claim their systems are "outdated" or that they're using "usual and customary" rates, all while you have a signed agreement showing current rates. The claim gets paid at the lower rate, and when you ask why, they blame "system limitations" or "the fee schedule we have on file."

This is the "shell game." Your contract says one thing, but their payment says another. And they're betting you won't have the documentation to prove the discrepancy.

Common Excuses

  • • "Fee schedule on file is outdated"
  • • "System limitation prevents update"
  • • "Usual and customary rate is lower"
  • • "Negotiated rate not yet in system"

The Impact

  • • 5-15% systematic underpayment
  • • Affects all claims from that payer
  • • Compounds across patient volume
  • • Difficult to dispute without proof

Why It Works

  • • Providers often lack fee schedule proof
  • • Carriers control "system" narrative
  • • Payments are made (not denied)
  • • Requires proactive audit to detect

Your Defense: Fee Schedule Mastery

1

Request Fee Schedules in Writing

Every time you negotiate or update a rate agreement, request the fee schedule in writing with an effective date. Don't rely on verbal agreements or email confirmations. Get it on the carrier's letterhead.

Action: Send a formal letter requesting confirmation of all agreed rates and effective dates. Keep copies.
2

Conduct Fee Schedule Audits

Quarterly, compare a sample of paid claims to your documented fee schedules. Track the variance. If the carrier is paying below your agreed rate, document it with dates and amounts.

Action: Create a variance report showing discrepancies. Send it to the carrier's billing department with a request for explanation.
3

Build Demand Letter Packages

When you identify systematic underpayment, build a demand letter package with: (1) your signed agreement, (2) paid claims showing underpayment, (3) variance calculations, (4) demand for payment plus interest.

Action: Prepare a demand letter for any payer with 5%+ variance. Send via certified mail.

The Legal Angle

Most states have prompt payment laws that require payers to pay according to the agreed fee schedule. If the carrier has agreed to your rates but is paying less, they're in violation. Your signed agreement is your legal proof.

In many states, you can file a complaint with the Insurance Commissioner or pursue a small claims action for systematic underpayment. The key is documentation: keep every fee schedule, every paid claim, and every variance.

Providers who build a strong demand letter package with documented evidence of systematic underpayment and reference to applicable state prompt payment laws often prompt carriers to settle rather than face regulatory scrutiny.

Fee Schedule Audit Template

Download our template for conducting quarterly fee schedule audits and building demand letters

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