Perspective | Can fees for equipment usage be charged in clinical diagnosis and treatment?
Published:
2025-11-24
When conducting certain clinical examinations, medical institutions need to use specialized instruments and equipment. If such equipment has a corresponding fee item in the catalog of charges for medical services, can the medical institution independently charge a fee for the use of the equipment? Different medical institutions hold varying views on this issue, and in practice, it is not uncommon for institutions to be penalized by the administrative authorities responsible for medical insurance funds for charging such equipment-use fees. Drawing on my long-term experience in handling cases, I will attempt to analyze whether such fees can indeed be charged.
When conducting certain clinical examinations, medical institutions need to use specialized instruments and equipment. If such equipment has a corresponding fee item in the catalog of charges for medical services, can the medical institution independently charge a fee for the use of the equipment? Different medical institutions hold varying views on this issue, and in practice, it is not uncommon for institutions to be penalized by the administrative authorities responsible for medical insurance funds for charging such equipment-use fees. Drawing on my long-term experience in handling cases, I will attempt to analyze whether such fees can indeed be charged.
I. Case Introduction
A certain hospital performs Fiber colonoscopy At the time, in addition to collecting the fee for the fiber colonoscopy examination itself, the hospital also charged a separate fee for the use of the fiber colonoscope equipment. The administrative department of the medical insurance fund held that since the fee for the fiber colonoscopy examination had already been collected, it was improper to charge an additional fee for the use of the fiber colonoscope. Therefore, the hospital’s practice of charging a separate fee for the use of the fiber colonoscope equipment constituted double billing. Consequently, the hospital was ordered to refund the corresponding amount from the medical insurance fund and was also fined accordingly.
The hospital, however, argues that the item for “use of surgical instruments and equipment” stipulated in Article 3317 of the “Price List for Medical Service Items of Public Medical Institutions in Shandong Province” (hereinafter referred to as the “Medical Service Item Price”) explicitly identifies “fibrocolonoscopy” as a separately chargeable item. Since a fibrocolonoscope was used during the fibrocolonoscopy examination, it is only natural that the fee for fibrocolonoscopy could be charged.
II. Case Analysis
Under Item 3, “Clinical Diagnosis and Treatment for Various Systems,” of the “Prices for Medical Service Items,” Article 5 stipulates that “for various endoscopic treatments performed during diagnosis and treatment, an additional fee may be charged on top of the original price; the specific amount of the additional fee is indicated in ‘3317.’” The operational steps for “Fiber Colonoscopy” include: cleansing the bowel, administering sedation, lubricating the intestinal tract, inserting the colonoscope through the anus, advancing it along the lumen to the ileocecal junction, and examining the entire colonic mucosa. (National Technical Specifications for Medical Service Items [2023 Edition], FPS1A601) According to the “Prices for Medical Service Items,” “Fiber Colonoscopy” falls under the category of clinical diagnosis and treatment for various systems, and since the procedure involves the use of a colonoscope, does this imply that an additional fee for colonoscope usage can be appropriately charged when performing this procedure? Is there an error in how the administrative department responsible for medical insurance funds has handled this matter? To address this question, we can analyze the issue by starting with the regulation itself and the characteristics of colonoscopy procedures, employing methods such as textual interpretation.
(1) Treatment procedures may be charged for, but examination procedures may not be charged for.
The “Price List for Medical Service Items” stipulates that “when various endoscopic treatments are employed during diagnosis and treatment, an additional charge may be levied on top of the original price.” Here, it does not directly state that “an additional charge may be levied on top of the original price whenever various endoscopes are used during diagnosis and treatment”; rather, it specifically states that “an additional charge may be levied on top of the original price only when various endoscopic treatments are employed.” This indicates that not all diagnostic and therapeutic procedures involving endoscopes are eligible for an additional charge for endoscope usage. According to the... Implementation Rules for the Administration of Medical Institutions According to Article 88, medical diagnosis and treatment activities refer to actions undertaken through various examinations, the use of medications, medical devices, surgical procedures, and other methods, aimed at making a diagnosis of diseases, eliminating diseases, alleviating symptoms, reducing pain, improving bodily functions, prolonging life, and helping patients recover their health. As can be seen, the term “diagnosis and treatment” is composed of two components—“diagnosis” and “treatment”—and encompasses both the aspects of examining conditions and treating diseases. Under the category of “Clinical Diagnosis and Treatment for Various Systems,” there are two main types of services: diagnosis and treatment. For example, under the item “Digestive System,” procedures such as “Fiber Gastroduodenoscopy” and “Fiber Colonoscopy” fall under the category of diagnostic services, whereas “Endoscopic Intestinal Stent Placement” and “Special Endoscopic Therapies” belong to the category of treatment services. The “Price List for Medical Service Items” stipulates that “for various endoscopic treatments performed during diagnosis and treatment, an additional fee may be charged on top of the original price.” This provision emphasizes that only those treatment procedures involving the use of various endoscopes are eligible for the additional charge for endoscope usage; even if diagnostic procedures utilize corresponding endoscopes, no additional fee may be levied for their use.
Fiber colonoscopy involves inserting an endoscope through the anus to examine the inside of the large intestine (colon and rectum). It should be considered a diagnostic procedure rather than a therapeutic one; therefore, no additional charge should be levied for the use of the endoscope itself. The hospital’s view—that “as long as the equipment is used, charges can be collected according to the fee schedule”—confuses the distinction between “the existence of a chargeable item” and “the fulfillment of the conditions for charging.” The inclusion of “fiber colonoscopy” as a chargeable item in the “Prices for Medical Service Items” establishes the fundamental prerequisite for charging fees for this equipment; it merely indicates that the equipment fee can be collected separately under specific applicable conditions. Fulfilling these charging conditions constitutes the minor premise for collecting the equipment fee—specifically, the minor premise for charging equipment usage fees under various clinical diagnostic and therapeutic procedures involving endoscopes. For example, 310903008, Endoscopic Placement of an Intestinal Stent, is a procedure in which a stent is placed via colonoscopy into the narrowed segment of the colon to restore patency of the digestive tract. This procedure is indicated for colonic obstruction or stricture. Palliative care The project meets the minor premise that a surcharge for colonoscopy use can be applied. The hospital’s charge for “fiberoptic colonoscopy” only considered the major premise—that is, the equipment itself—while overlooking the fact that this project does not meet the minor premise of being suitable for endoscopic treatment. Therefore, the handling by the administrative department of the medical insurance fund is in compliance with the provisions of the medical insurance policy.
(2) The inspection items include equipment usage fees; treatment items are not included.
To standardize the management of medical service price items, ensuring that these items are better priced, more effectively implemented, and easier to evaluate, the National Healthcare Security Administration has successively developed several guidelines for initiating new clinical treatment projects. Among these, the "Guidelines for Initiating Medical Service Price Items in the Digestive System" (hereinafter referred to as the "Guidelines") stipulates that for endoscopic treatments or surgical procedures within the Department of Gastroenterology covered by these Guidelines, if related endoscopes are required, the associated endoscopy fees may be charged separately. This provision indicates that... Endoscopic Digestive Therapy The benchmark price for the project does not include the equipment usage fee for the relevant endoscope, whereas the price for gastrointestinal endoscopy procedures does include such a fee. If the price of the treatment procedure already covers the endoscope usage fee, then the Guideline would have been entirely unnecessary to go to the extra trouble of specifically authorizing hospitals to “charge an additional equipment usage fee based on the examination fee standard” during treatment. On the other hand, if the examination procedure does not include the endoscope’s equipment usage fee, then the Guideline’s provision to charge the endoscope’s equipment usage fee according to the corresponding examination fee standard would be groundless.
III. Attorney’s Recommendations
Clinically commonly used endoscopes generally serve both diagnostic and therapeutic purposes. For example, colonoscopy can be used to detect intestinal lesions—for instance, by visually examining the colonic mucosa to identify polyps and early-stage cancers, and by taking biopsies for pathological analysis. Moreover, colonoscopy can also be employed to treat certain intestinal lesions: benign lesions such as colorectal polyps can be directly removed under endoscopic visualization, and endoscopic hemostasis can be performed to stop intestinal bleeding. Given the numerous diagnostic and therapeutic procedures listed above, the device... Endoscopic equipment Due to the complexity and diversity of medical practices, healthcare institutions often find it easy to charge fees for equipment usage alongside consultation services. To ensure that charges for surgical equipment usage are reasonable—avoiding penalties from the administrative authorities overseeing the medical insurance fund and preventing financial losses—healthcare institutions should accurately distinguish between diagnostic and therapeutic procedures. Specific recommendations are as follows:
(1) Establish principles for determining fees.
Before and during the billing process, determine whether a medical procedure constitutes an examination or treatment based on the essential purpose of the medical act.
Diagnostic behavior: The core objective is “obtaining information and establishing a clear diagnosis,” and the actions involved are “observation” and “sampling” (biopsy). No matter how challenging the procedure may be, as long as its ultimate goal is to provide evidence for pathological diagnosis, it remains classified as an examination. For example, even if a complex technique is employed to reach a narrow site and obtain a biopsy, the procedure’s essence is still that of an examination.
Therapeutic behavior: The core objective is to “intervene in the lesion and alter the disease course,” with actions aimed at “excision,” “repair,” “hemostasis,” “dilation,” and “implantation,” among others. For example, snare polypectomy for polyps, electrocoagulation or titanium clip closure of bleeding points, balloon dilation of narrowed intestinal segments, and stent placement—all fall within the scope of therapeutic interventions.
(2) Establish a reasonable fee mechanism.
Based on the principles outlined above, medical institutions can establish a “dual-check” mechanism to prevent instances of duplicate billing.
Clinical Decision Verification: When issuing medical orders or performing procedures, physicians must clearly state the primary objective of the current procedure. In electronic medical records or procedure logs, it is essential to clearly indicate whether the procedure is a “diagnostic examination” or a “therapeutic intervention.” For mixed procedures that involve both diagnostic evaluation and treatment, each component must be recorded and billed separately. For example, during a colonoscopy, one polyp was identified intraoperatively, and an endoscopic polypectomy was subsequently performed.
Fee Item Verification: The medical insurance and price management authorities should provide a clear correspondence table. For example, “fiberoptic colonoscopy” should be explicitly labeled as “bundled price—no additional charges for equipment fees.” Treatment-related items such as “endoscopic colonic therapy” should be linked to the item allowing for additional charges for equipment usage, clearly stating that “equipment usage fees may be collected in accordance with regulations.”
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