Informed Financial Consent: What Every Doctor Needs to Know About Ethical Billing
July 17, 2025
If you’re a medical professional working in private practice, ethical billing may not be top of mind in your day-to-day. But it should be. Patients are becoming more aware of their rights. Complaints to the Health Professions Council of South Africa (HPCSA) about billing are rising.
The council has responded with an update to their Booklet 19: Guidelines for Ethical Billing Practices, which now provides clearer, consolidated guidance on ethical billing and financial consent.
Billing isn’t just a financial matter. It’s an ethical one. And informed financial consent lies at the heart of it. This blog will walk you through what it means, where doctors often go wrong, and what HPCSA expects you to do to stay compliant and trusted.
What Is Informed Financial Consent, and Why Does It Matter?
Informed financial consent means explaining all costs to the patient before providing treatment. That includes consultation fees, possible procedures, additional diagnostics, co-payments, and what portion will (or won’t) be covered by their scheme.
It’s not just good etiquette. It’s codified in HPCSA Booklet 19, which draws from the National Health Act, the Health Professions Act, and ethical guidelines on patient rights.
Patients have a right to:
Understand what they are paying for
Refuse treatment based on cost
Get a written breakdown of fees, payment obligations, and billing codes
Failing to obtain financial consent undermines patient trust and can result in serious regulatory consequences.
Common Pitfalls and Misunderstandings
Many billing disputes arise not from malice but from miscommunication or assumptions. Common issues include:
Split billing: Giving one invoice to the scheme and another to the patient. This is prohibited.
Not explaining co-payments: Patients often don’t realise they’ll owe more until the invoice arrives.
Assuming “they already know”: Especially with scheme patients. But it’s your responsibility to make sure they do.
Verbal-only consent: Without documentation, you have no proof that the patient agreed.
Omitting associated costs: Such as labs, anaesthesia, or prosthetics, even if not billed directly by you.
In short, the burden is on the practitioner to ensure clarity upfront.
What Booklet 19 Requires You to Do
Booklet 19 offers practical, codified expectations. Here’s what it requires:
Have a documented billing policy: This should explain how fees are calculated (e.g. time, complexity, national benchmarks) and applied.
Get written informed financial consent: Especially for each new procedure or if costs change.
Disclose all costs:
Consultation
Procedures and additional services
Co-payments or scheme shortfalls
Non-medical aid portions of composite care (e.g. anaesthetist or pathologist)
Only charge in advance in limited cases:
Foreign patients
Co-payments on planned procedures
Custom medical devices or prostheses
Use balance billing — not split billing: The scheme and patient must both receive a full invoice, clearly showing what each is responsible for.
Give detailed invoices and statements: Include itemised charges, ICD-10 codes, contact details, and payment terms.
How to Make Ethical Billing a Seamless Part of Practice
Following the rules doesn’t mean adding admin headaches. With some smart habits, informed financial consent can be built into your normal routine:
Create a simple billing policy: Include it in your intake documents and patient communication.
Train front-line staff: Make sure reception and billing teams can explain fees clearly.
Use templated consent forms: Especially for common procedures. Customise as needed and keep them on record.
Document everything: If you have a conversation about fees, note it in the clinical record.
Direct patients to external cost providers: You don’t need to quote on pathology, but you must tell patients where to get those costs.
Ethical billing starts with transparency and ends with patient trust. And the more structured your approach, the easier it becomes.
Final Word: Clarity Builds Confidence, for You and Your Patients
Most doctors strive to do the right thing. Booklet 19 is not a punishment: it’s a practical framework for protecting yourself and your patients.
When billing is transparent, consistent, and well-documented, complaints decrease, and trust grows. You don’t need to be a legal expert to comply; just build good habits, keep clear records, and get the right support.
At Vizibiliti, we help medical professionals put these principles into action — with no stress, no drama, and full peace of mind.
