The employer pays for the membership, but the care belongs to the patient. Share totals that help the employer judge the program, like enrollment and visit counts, and never anything that identifies an individual's care. Be careful with small groups, where a total can point to one person.
What employers usually want
- How many employees enrolled.
- How many members used the practice.
- How quickly members got appointments or replies.
- Whether the program is worth renewing.
All of these can be answered with totals.
What not to share
- Who visited, when, or for what.
- Diagnoses, medications or referrals for any employee.
- Lab or medication charges listed by employee.
- Anything an employer asks for "only for this one person."
Watch small numbers
In a group of eight, a line saying "one specialist referral for back pain" may point to a person everyone knows. Set a minimum before you report a category, like at least 10 members in the group and at least 5 in any count. Below that, report the total visits only, or skip the category.
Invoices count too
An invoice lists who is enrolled, which the employer already knows. It shouldn't list services by person. If you bill extras to the employer, show a total for the month. Here's what an invoice should show.
Know the rules that apply to you
Which privacy laws apply to your practice depends on how you operate, including whether you bill insurance. State law may add its own rules. Ask your healthcare attorney what applies, and put your reporting limits in the employer contract so the employer knows them in advance.
What I'd do this week
- Review the last report you sent each employer for anything that could identify a person.
- Set a minimum count for reporting categories.
- Add a short privacy section to your contract template, reviewed by your attorney.
Common questions
Can I tell an employer whether a specific employee enrolled?
If enrollment is part of billing, the employer knows who's enrolled. Whether and how they visited is not theirs to know.
What if the employer insists?
Point to the contract and your privacy policy. If they keep pushing, talk to your attorney.
Can employees agree to share their information?
That's between the patient and you, with proper written consent. Ask your attorney before relying on it.
Want employer billing that stays private by design?
We reconcile every account every month and send your P&L and Balance Sheet by the 15th, so decisions like this start from real numbers. If that's what you need, apply to work with us.