Newsletters

Government Hospital Organizations and Consequences of 501(r) Non-Compliance

Nick McLaughlin

Regional Director of Ridiculously Nice Sales at Americollect

Many government hospital organizations were told they were off the 501(r) hook in 2016. New guidance from the IRS significantly narrows that loophole, and one unnamed county hospital has already had it’s 501(c)(3) status revoked. In the redacted tax status letter to the hospital, IRS officials stated that the hospital’s failures were “egregious,” and that “the organization’s administrators made it clear that [the hospital] had neither the will, the financial resources, nor the staff to follow through with (501(r) requirements”. Loss of the 501(c)(3) exemption eliminates a hospital’s ability to use certain employee benefit plans, subjects hospitals to income, property, and other taxes, disallows receipt of tax-deductible contributions, and bars use of tax-exempt bonds.

For those unfamiliar, 501(r) requires hospitals to standardize billing and collection policies, conduct Community Health Needs Assessments (CHNAs), respond to the needs found in the CHNA, and proactively notify patients of the availability of financial assistance – all in order to justify tax-exempt status. According to the IRS clarification, unless your hospital is not recognized as tax-exempt under Section 501(c)(3), you are required to comply with the 501(r) regulations.

One common question has been, “What if I don’t have to file a Form 990?” There are a handful of hospitals that are excused from filing a Form 990 under Revenue Procedure 95-48 and the Affordable Care Act did not change the requirements regarding which organizations are required to file a Form 990. That said, the IRS made it clear that in order to be treated as described in section 501(c)(3), “government hospital organizations still must meet all section 501(r) requirements that do not involve disclosure on or with the Form 990, including making their Community Health Needs Assessment reports and Financial Assistance Policies widely available on a website.”

So, if you’re saying to yourself right now, “Well, I guess we have to do this thing but where do I start?” We are here to help! Our team has helped hospitals across the U.S. get up to speed with 501(r) absolutely free. Our only ask is that the next time you’re looking for a new Early Out or Bad Debt partner, you give us a chance to show you the difference Ridiculously Nice can make! On our website, www.americollect.com/501r, you will find an entire bootcamp regarding 501(r) compliant Financial Assistance and Billing and Collection Policies, what you need to add to your current Collection Agency Agreements for 501(r) compliance, as well as how to comply with the “Reasonable Efforts” and “Widely Publicized” requirements. Also available there are recorded webinars that cover Financial Assistance Policy requirements as well as the regulations around Extraordinary Collection Actions. The resources are extensive, helpful, and we encourage you to take advantage of them! In addition, Americollect will be hosting our popular two-part webinar series on 501(r) readiness February 26th and March 5th.  Please feel free to contact us for more information at sales@americollect.com.

Please don’t hesitate to reach out to us with any questions you may have. We are here to help and would love to connect with you to assist you in getting up to speed with the wonderful adventure of 501(r)!

Link to the letter: https://www.irs.gov/pub/irs-wd/201731014.pdf

Link to updated guidance: https://www.irs.gov/charities-non-profits/section-501r-reporting

 

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Reassigned Number Database – Your Hands are Dirty! Go Scrub Them

Kenlyn T. Gretz, CEO – Americollect 

As a parent of young children, you’ll know this command well – “Your hands are dirty, go scrub them”. Be it mud or marker, a child regularly comes to the dinner table with dirty hands. Well, the Federal Communications Commission (FCC) issued its first command to go and scrub! They are asking all that use automated dialing equipment (appointment reminders, collection calls, and marketing calls) to go scrub your phone numbers to their Reassigned Number Database (RND).

According to YouMail, in 2018, an estimated 48 billion robocalls were placed to cell phones. This is up 60% from 2017. The jump has placed more attention on all phone calls to cell phones, even legitimate calls from your organization.

The FCC is trying to tackle this problem issue by issue and one of those issues is reassigned phone numbers.  According to the FCC, approximately 35 million telephone numbers are disconnected and aged each year. Along with this, wireless carriers reassign approximately 100,000 numbers every day and normally after only 90 days.

How does this apply to hospitals? When the owner of the wireless number changes, so does the permission tied to the number according to the Telephone Consumer Protection Act (TCPA). A short recap on TCPA: If a patient gives you a phone number, you can use an auto-dialer to call or text it for medical purposes. If for collections or marketing purposes, we highly recommend having language in your admission contracts to achieve the “express permission” required by the law. But having permission or having been provided a phone number by the patient does NOT protect you when the phone number now belongs to a new party; this is called phone number reassignment.  The new owner of that wireless number has NOT given you permission.   This is where TCPA liability can stack up big at $500 per phone attempt by automated telephone dialing systems (ATDS) regardless if it is for medical, collection, or marketing purposes.

In 2015, FCC attempted a solution of “one chance” to dial a reassigned number. The FCC stated that “callers who make calls without knowledge of reassignment and with a reasonable basis to believe that they have valid consent to make the call should be able to initiate one call after reassignment as an additional opportunity to gain actual or constructive knowledge of the reassignment and cease future calls to the new subscriber.” In 2018, this “one chance” was removed as part of litigation against changes to the TCPA by the FCC. The problem with a “one call” safe harbor is that a majority of “informational” phone calls are done with prerecorded messages. These prerecorded messages aren’t able to determine if they are calling the right party. This was great news for all that make phone attempts to consumers.

The second solution is that the FCC will create a reassigned number database (RND). All companies will need to search this database before making an attempt. The wireless numbers are to be checked along with the last date the caller verified the number belonged to the patient.   For example, a provider would send phone number 920-682-1234|09-13-2018 where the date of service was 9-13-2018.  You will receive back one of three options:

  • No – the phone number has not been reassigned since 9-13-2018
  • Yes – it has been reassigned since 9-13-2018, you will want to stop dialing/texting
  • No data – the phone number is not in the database

The FCC also added a safe harbor for callers using the new database. This safe harbor provides protection from TCPA liability when “database errors” lead to an incorrect call to a consumer. This means the scrub needs to be stored.

Sounds simple right? Well it is not, because Americollect has been performing this scrub for several years. In most Electronic Health Record (EHR) systems, there are locations for multiple phone numbers; work, home, or cell.  Few systems, if any, have a logging date of when that phone number was last “verified.”   Americollect and our software provider, Roydan, have been working on this issue for a few years and we have this built into our solution.  It is called “Contact Tracker”. With it, we log every time we “verify” the phone number, the source of where we received the number, if it is a cell phone, and other self-defined types of phone attributes. We also have the ability to know who the subscriber of the phone number is, and we monitor the subscriber ownership before we dial it.  We stop dialing phone numbers when they have been reassigned to a new subscriber.  So, the very proposal the FCC has put forth is something we have been doing for four years.

The difference is that the reassigned number database will probably be more accurate than our source of subscriber ownership.  We view this reassigned number database as an additional tool to improve our current process.

What can hospitals do to help?

First, build a field in your EHR system to log the verified number and date per phone field. With this you will need to define:

  1. Did your staff actually talk to them at that number?
  2. Was it the last date of service?
  3. Was it a face-to-face admission?

Once you have that date, then share with your vendors who help you make phone calls and texts. We realize this may not be a priority for you to create new fields in the placement or update files, but it will save us both a lawsuit!

So, go scrub! It will be good for all who are tired of robocalls!

If you would like to know more about the TCPA and reassigned number database, please reach out to Kenlyn Gretz at Kenlyn@americollect.com.

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Transparency and Choice in Patient Financial Communications

Nick McLaughlin, Ridiculously Nice Sales and Business Development – Americollect and
Daniel Harris, Vice President Business Development – Apex Revenue Technologies

“In five years, the mailed patient statement will be dead.” “In ten years, ninety percent of your communication with patients will be via text message.” I have heard these claims made at conferences and in newsletters the last few years, but I’m not taking the bait to that extreme. It’s true, adoption of electronic notification (e-notification) of patient financial responsibility is growing more quickly than many anticipated. And it’s growing for some very interesting reasons that may seem counter-intuitive at first. This article will explore what we have observed in the marketplace, and what you can do to be prepared for the demands of tomorrow’s patients.

History
So what exactly is e-notification of patient financial responsibility? Nickster’s Dictionary defines it as “an email or text message notification to patients that lets them know that they have a bill, and includes a link to view that statement in an internet browser or mobile device.” Since e-notification options became available through the more innovative statement providers in the healthcare space, patient adoptions of these functions has been steady, but slow. Over the last ten years, providers that offer these options to patients have seen an adoption rate near 1%, maxing out at 4-5%. But in the last two years, growth in adoption rates has grown significantly with some providers seeing 10-15% adoption, and trending toward 25%.

Tipping Point?
Not only are some providers seeing 10-15% adoption of e-notifications and growing, they are also seeing as high as 20% of all patient payments coming in via mobile devices. Why so much growth all of a sudden? The theory was that e-notifications would become more popular as Millennials and Gen X-ers age into our healthcare systems, while the elderly have less patient responsibility. However, this theory did not take into account the widespread adoption of smart phones and technology by the Baby Boomer generation and older. (Haven’t you noticed grand-parents spending just as much time fiddling with their phones these days as teenagers?) Baby Boomers make up the largest percentage of our patients these days, and their growing comfort with technology and trust in technology has brought them to want to take advantage of the convenience e-notifications offer.

Why Not 100% Adoption?
Adoption of a more convenient and trustworthy option for notification of patient financial responsibility should just keep on growing until everybody uses it, right? We don’t think so. The fact remains that a very high percentage of the services done at hospitals are acute and unplanned. Our research shows that nearly 60% of the communications sent are for a single episode of care, and to a patient who has not been to the facility in over a year. In the world of e-commerce or online banking, if I use that website or bank regularly, chances are that I am going to “register” at checkout and take advantage of the conveniences that come along with that. Alternatively, if I’m buying something on a website that I don’t think I’m going to use again anytime soon, I’m probably just going to check out as a “guest.” We expect that pattern to apply to patients as well: regular patients will adopt e-notifications at a higher rate than patients who rarely come to the hospital.

Be Prepared
As electronic adoption continues to rise amongst all generations of patients, it is important that basic principles of consumerism be applied to the patient financial experience. Research shows that a patient can have an outstanding clinical experience with a provider, but if it is followed by a poor billing experience they are less likely to return to that provider for services in the future.

What does this look like in practice? Transparency and choices. Allowing patients the ability to easily manage their communication and payment channel preference will not only lead to a better patient overall financial experience , it will also lead to more patient payments being collected and increased rates of patient satisfaction.

98% of text messages are opened. The majority of these text messages are viewed in under 3 minutes. While electronic communications are not a perfect fit for every patient, offering them as a choice to the patients we have the pleasure of serving will not only lead to better results for all parties involved.

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The Importance of Social Security Numbers in Self-Pay Collections

Jody Heard,
Regional Director of Ridiculously Nice Sales

In today’s environment of rampant identity theft and data breaches, many organizations are reevaluating what patient data they truly need to collect and store in order to perform their day-to-day operations. One such piece of information that is under the microscope is Social Security Numbers (SSNs). The reason that SSNs are under scrutiny today, is because the Centers for Medicare and Medicaid Services (CMS) is currently issuing new Medicare cards which replace the SSN-based Health Insurance Claim Number (HICN) with a new Medicare Beneficiary Identifier (MBI). Along with this change, you have most likely seen the headlines and articles which quotes CMS Administrator, Seema Verma as saying, “We’re taking this step to protect our seniors from the fraudulent use of SSNs, which can lead to identity theft and illegal use of Medicare benefits.” These two facts taken out of context have led many to believe that utilizing SSNs in healthcare is toxic.

What we need to understand though, is that it was not CMS’s use of SSNs that caused issues, but the way in which they utilized them. CMS’s choice to openly display the HICN/SSN on the front of all Medicare cards, a card which many seniors keep in the front of their wallet inadvertently displaying their SSN throughout the day to any number of strangers, caused the issues and the potential for identify theft. In fact, according to the Office of the Inspector General (OIG), “For more than a decade, we and other Federal agencies recommended taking SSNs off of Medicare cards, to limit identity theft and Medicare fraud against seniors.” I will point out that the OIG recommended removing SSNs from the Medicare cards, not eliminating the use of them.

Accurate Identification
SSNs play a vital role in correctly identifying U.S. citizens and in healthcare, your patients. This becomes especially important as you consider the back-end of your revenue cycle process or more specifically, self-pay collections. The ability to correctly identify the appropriate patient while collecting self-pay balances reduces cost and increases collection rates while minimizing exposure to litigation. SSNs are required for many of the processes that your self-pay vendors utilize. When you neglect to provide that information, your vendors are forced to rely on less accurate processes like matches based on name and date of birth. Now if you consider that according to Ancestry.com there are 38,313 James Smith’s, 34,810 Michael Smith’s, and 32,092 Maria Garcia’s in the U.S., the likelihood of getting the wrong match with only a name and date of birth exists. Having a wrong match can lead to, in the best case, an uncollectable account or poor patient experience. In the worst case, litigation.

Our Processes
The following are just a few examples of the processes that Americollect utilizes which require SSNs. Because these searches require the SSN, we are unable to perform them for organizations not providing it.
• Known Litigant Search – Identifies patients whom frequently sue collection agencies. These accounts are handled by specialists in this area reducing the likelihood of future litigation.
• Title 19 Search – Identifies patients whom fall under Title 19.
• TRIP (Tax Refund Intercept) Search – For states which offer this program, enables garnishment of tax refunds to pay outstanding medical bills.
• Credit Reporting – A SSN is now required in order to report on credit files.
• Insurance Eligibility Verification – When a potential insurance carrier is identified for an account, eligibility is validated before the client is notified, reducing the labor and cost for our clients.
• Presumptive Eligibility – For organizations that wish to implement a Presumptive Eligibility program, Americollect can help. Our account searches provide the due diligence necessary to score and identify accounts which would fall under presumptive eligibility. This process requires a SSN in order to be successful.

The following procedures do not require a SSN but are vastly more accurate when one is provided.
• Guarantor Level Grouping – Americollect groups all incoming accounts at the Guarantor level. This reduces the number of calls and correspondence that a household receives, greatly improving patient satisfaction and collection rates. If SSNs are not provided, this matching is not as accurate resulting in many accounts not being combined and patients receiving multiple phone calls and statements.
• Bankruptcy Search – Bankruptcy searches can be performed without a SSN; however, they are significantly less accurate resulting in an increased litigation rate.
• Deceased Search – Deceased/Probate searches can be performed without a SSN; however, they are significantly less accurate resulting in an increased litigation rate.
• Skip Tracing – When skip tracing, use of the SSN provides a significantly better chance of locating a correct address and phone number.

Now that you understand why a SSN is important to your self-pay process, we should also discuss your staff’s largest barrier to getting it – the patient. As identity theft has grown across the nation, the public has become educated on the dangers of providing their SSN. As a result, your staff may encounter push-back from your patients when requesting this information. Two approaches that we have seen work well in this discussion with the patient are as follows:
• Privacy – To protect your privacy, we utilize your SSN to validate your identity when speaking with you. Your SSN is one of the only numbers that you, and you alone know, allowing us to verify that you are you before discussing your sensitive personal health information.
• Credit – We need your SSN because we are extending you credit for our services. Once your portion of the bill comes due, we need to make sure that we can collect on it. This is just like when you apply for a loan or a credit card with a bank and your SSN is the first number that they ask for.

By providing your self-pay vendors with the correct SSN for your accounts, you ensure accurate, timely, and effective debtor identification while reducing cost, increasing collection rates, and minimizing exposure to litigation. You should also remember that your self-pay vendors are trusted partners of your organization whom you rely on to protect the PHI of your patients. If you cannot trust them to protect your patient’s SSNs, should you really be trusting them with your PHI?

 

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Defense Wins Championships

Nick McLaughlin,
Ridiculously Nice Sales and Business Development

The old sports cliché gets repeated every time a new sport enters championship season. But when it comes to collecting patient balances, playing defense with data has been the key to Americollect becoming a champion partner in Early Out and Bad Debt Collections. We receive thousands of patient records from our clients every day, and if something goes wrong in the data export, transfer, or programming process, we could be trying to collect balances from patients that don’t actually owe. Can you say FDCPA lawsuit?! NO THANKS!

At Americollect, we implement a number of programming measures behind the scenes to make our clients’ lives easier, our service more effective, and the data we use to collect 100% accurate. The majority of our clients’ systems export a data file with all the information we need to list the accounts in our system and begin collecting. Here are a few defensive programming tools we use that have proven helpful:

Duplicate Account Catcher
One of the first things we built into our programming was a duplicate account catcher. Sometimes our clients accidentally send over last month’s placement file that has already been loaded into Americollect’s system. Loading those accounts a second time would cause a big mess, but our duplicate account catcher matches the new file against what has already been placed, and kicks all duplicate accounts back.

Alpha Split
Clients of ours that use more than one agency often use an alpha split to send guarantors with last names beginning with “A-L” to one agency and “M-Z” to the other. When this is the setup, Americollect places programming to look at the names on the specified level (guarantor in this case) to make sure we are not receiving accounts outside of the predetermined alpha split. If any accounts are caught, an email is sent to the assigned member of our client’s team to let them know of the issue.

Mapping Tables
Many of our clients include location codes in the placement files for the different points of service their patients visit; for example, which hospital in the health system, which ambulatory surgery center, or which medical group. We use mapping tables so that our clients can view performance data by location, as well as data quality by location, so they can see which registration teams are doing a better job gathering up-to-date patient demographics at point of service.

Headings Compare
System glitches sometimes happen in the data files our clients export. These can occur from various causes, but whatever the cause, our job at Americollect is to make sure that we catch any data variances before they wind up as incorrect balances in our system. Defensively programming a Headings Compare process is the best tool to make sure we catch any glitches. While in the data testing process before going live, we use the headings provided to check each live data file going forward. If even one heading is off, the placement process will error out and catch any data shifting. We then go back to our client to resolve the issue and ensure the correct data comes into our system.

Guarantor is a Minor
Each time we place accounts, our programming runs a report that flags each account that has a guarantor under age eighteen. We send this back to see if there is another responsible party on file to then collect from.

State Specific Protections
Some states have laws that require providers to handle accounts a certain way. For example, in California, it is illegal to send accounts to a collection agency unless they are at least 120 days delinquent. We built programming for our California clients to check the date of delinquency against the date listed, and hold accounts until 120 days has passed in case they accidentally send an account early.

Special Acknowledgments
We like our clients to know the minute their accounts are listed in our office. To verify this, we generate an acknowledgment report immediately after accounts are listed to let them know the number of accounts, as well as dollar amount total of the file. This way our clients know right away if what has come into our system matches what they sent.

If you’re anything like me, I’m sure you find all of these super in-the-weeds details about how we protect our clients and their patients from data mistakes absolutely riveting! Well, maybe not riveting, but at least you can rest at ease knowing that at Americollect, we go above and beyond to play great defense. And together we can be champions!

 

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Three Years of Web Chat at Americollect

Shawn Gretz,
President

Can’t I just text you?”…. asked our 14 year-old babysitter. It is not surprising she would ask us this question according to a recent survey by OpenMarket. When given the choice between being able only to text versus call on their mobile phone, a whopping 75 percent of millennials chose texting over talking. As younger generations grow-up with the technology of today, communication by text is becoming the preferred method. It turns out that both introverts and extroverts are apprehensive of phone calls these days. The reluctance to talk on the phone is born out of the fear that you will not be able to represent yourself well in a phone conversation, which causes stress especially in sensitive conversations about medical bills. Individuals today will happily online-chat away to avoid the dial-fright!

This is why three years ago, Americollect invested in our next channel of communication – Web Chats. We decided to provide a better patient experience by making it easier for patients to chat with Americollect online. The great thing about Web Chats is that we can still verify the identity of the patient with dual authentication along with following all the regulations of the Fair Debt Collections Practices Act (FDCPA) in regards to all notifications.

By the end of 2018, we are trending to receive over 1,000 communications per month with patients. Currently just over 50% of our communications are promises to pay with simple questions on how to pay and/or arranging payment plans. We have collected an average of $47,000 per month over the last three months over Web Chats.

We are in the beginning stages of rolling this technology out to our early out clients as well to ensure the best patient experience as a 1st party operating in the name of the health system.

Below is a snap shot of a recent conversation clearing up a balance of $168.89.

[11:51 AM] Jody has joined the room.

[11:51 AM] Mary H has joined the room.

[11:51 AM] Mary H: Hello. My name is Mary. I will be happy to help you, today. One moment while I look up your account.

[11:51 AM] Jody: Ok

[11:51 AM] Mary H: What is the phone number we tried to reach you at?

[11:51 AM] Jody: XXX-XXX-XXXX

[11:52 AM] Mary H: What is our date of birth?

[11:51 AM] Jody: XX/XX/XXXX

[11:53 AM] Mary H: For future reference, your file number is XXXXX. Your current balance is $168.89. This is an attempt to collect a debt from a debt collection agency and any information obtained will be used for that purpose.

[11:55 AM] Jody: Ok, what can I do to get this cleared up?

[11:56 AM] Mary H: You can set that payment up online right now at www.americollectpay.com. The following is your login information. They are case sensitive.

User ID: XXXXXX

Password: XXXXX

[11:56 AM] Mary H: I will stay in chat in case you have questions about logging on.

[11:56 AM] Jody: Ok, I will do that now.

[11:57 AM] Mary H: 🙂

[11:57 AM] Jody: Will I be able to make payments? I won’t be able to pay the entire amount at once.

[11:59 AM] Mary H: You can certainly do that. The first payment option is payments of $56.30. Or, if you are able to pay half down of $84.45, then your payments would be $28.15 after that half down.

[12:00 PM] Jody: I made a $25 payment.

[12:01 PM] Mary H: This account is due to list on your credit file by  4/13/2018, so you do have some time to get it cleared up before it would list.

[12:01 PM] Jody: I will most certainly have it cleared long before that.

[12:01 PM] Mary H: Sounds good! 🙂 Is there anything else that I can help you with today?

[12:03 PM] Jody: Ok, thank you. You have been of great assistance and thank you for being patient with me getting this taken care of. Have a great day.

[12:04 PM] Mary H: You are so very welcome, Jody. You have a good day, as well. Thank you for taking the time to discuss your account today. I was happy to assist you with any questions or concerns you had. If you are in need of additional assistance, please feel free to contact me again via chat, or call my office at 888-682-0396, Monday – Friday 7:00am – 11:00pm, Saturday 8:00am – 5:00pm CST.  For residents of Wisconsin: This collection agency is licensed by the Division of Banking in the Wisconsin Department of Financial Institutions, www.wdfi.org

[12:05 PM] Jody has left the room.

This quick Web Chat conversation with the patient resulted in payment of our clients’ account, and the patient being able to take care of this bill when it works best for them, in a way that is easy for them to use. Up next on our channel of communication is solving for texting while staying compliant with the regulations!

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The Last Resort

Shawn Gretz,
President

“The Last Resort” is a saying that describes the only option left on the table. It is when everything else has failed. It is the least preferential (and in some states for healthcare collections not allowed) option.  But…in our opinions, it is worth pursuing if done right and gone through a stringent well documented process as it has the ability to change the present and train a patient for the future. At Americollect, we consider legal actions for collections a “last resort” to recovery if used ethically and legally, but before you become close minded to this option, let me ask that if I promised you that I could collect 87% of accounts would it change your mind? This is the case for the subset of accounts that Americollect takes legal action on.  The reason for such success in collecting these accounts comes down to the process Americollect puts in place before we ever consider sending a suit authorization to our clients.

Before we begin discussing, let’s look at what we feel is the wrong way to pursue legal.

  1. Legal Logo Statement – The quickest way some of our competitors increase their fees for collections is to have a healthcare provider sign a suit authorization and transfer an account to a legal law firm to send a statement to a patient. The statement/logo from the law firm is the scare tactic to try and collect the account. That letter will cost $0.60-$0.70 to send but will double the amount you pay for collection services. This is where the benefit of this statement goes away along with “scrubbing” the account for the correct patients to send this statement to. The bad publicity a hospital can receive by sending these statements to “every” patient will outweigh any recovery you will receive from it.
  1. Who Is Picking Your Battles – Any collector can let their emotions get the best of them and flip the work queue and sue a patient who was been disrespectful on the phone or argumentative about the service that has been provided. When you allow a collector’s emotions to get the best of them it creates the complex or competitive law suits where the cost to defend the suit against this patient will outweigh any benefit to collect the account. This is where the collector needs to be removed from the decision of which accounts are sued.

Americollect’s believes the right way to collect is for the collection agency to maintain the account and continue to be the call center while continuing to try to collect using stipulated agreements and any method possible before, during, and after the legal action occurs. This allows Americollect to control the patient experiences while the legal experts from each individual state use their expertise to take legal action. Below is our step-by-step process:

  1. Ridiculously Nice Collector Refers Accounts to Legal Team: Criteria for Ridiculously Nice Collector to refer an account:
  • The patient will have the ability to pay, but is choosing not to pay.
  • The patient will have defaulted on broken promises.
  • The patient is employed and worthy of garnishment (if legally available by state).
  • The collector does not believe the patient indigent or ill.
  • The patient is not highly disputing the bill or quality of services.
  • The patient owns property.
  • The patient has a minimum balance of $500.
  1. Legal Team Pre-Possible Suit Process: During this process, a more detailed check is done before we send our clients a suit authorization.
  • Minimum length of time listed based on Section 501(r)(6) IRS issued Notice 2011-52 to prevent extraordinary collection activities occurring before 240 days from the date of the first post discharged statement.
  • Bankruptcy scrub.
  • Formal employment verification.
  • Check if the spouse can also be included in the suit.
  • Active duty military at any point of account.
  • Credit score is checked for above the median.
  • Valuation of home is checked for above the median.
  • Child support payment check is completed.
  1. Suit authorization requested from our client.
  • Americollect matches subsequent referrals with the same defendant before suit.
  1. Legal Team Summons Steps: Once we get the signed suit authorization back, the following steps are completed to send a created packet over to the selected attorney’s office.
  • Documents signed suit authorization
  • Second verification of Step 2 -Pre-Legal Steps.
  • Final employment verification.
  • Sends to attorney for validation letter.
  • Creates, images, and prints itemized statement.
  • Redacts itemized statement.
  • Follows return date for entry of judgment.
  1. Process the account and all information to attorney of choice with a full reconciliation of all accounts to ensure timely filling of lawsuit.
  1. Post Judgment Steps: Once the judgment is entered, the following steps are completed.
  • The judgment is docketed as a lien in the county in which the judgment is taken.
  • If the patient has not called to set up a payment arrangement, a garnishment is filed against their wages.
  • Extended garnishments are sent to patients to sign. This saves them additional court costs.
  • Garnish bank accounts if needed.

The right way to use legal action results in 87% success for Americollect to collect the account. The bigger success is the ability to reeducate patients about the priority to pay their medical bills. Medical has regularly been found as one of the last bills patients will pay. While we don’t like to use legal action, we do feel there is a benefit to use it as a “last resort”.

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Mr. ROBOto

Shawn Gretz,
President

“The problem is plain to see, too much technology. Machines to save our lives, Machines de-humanize.”

Thank you Styx for the wonderful lyrics from Mr. Roboto to start a conversation about Robo-calls and the newest challenge for those of us looking to communicate with phones now protected by “robo-blockers.” Apple’s – App Store tells you just how big this challenge will be in the very near future. In October 2017, an app called Robo-Killer was introduced to the fanfare of many. As of January 2018, the app has been downloaded 12,900 times. The worst news for the call center industry is that this and several other “robo-blocker” apps combined together have over 150,000 downloads.

So what is a Robo-blocker app? Since early 2017, the Federal Communication Commission (FCC) has been working with tele-providers to start tracking robo-calls. They have created an entire database that is available to the public. This database has created a market for apps that intercept the call the moment your phone rings, and runs it through the database.

The database will:
1. Block any known spam numbers;
2. Notify you in the CallerID of any likely spam calls; or
3. Allow the call to come through.

If a person determines the call was spam, the app allows that person to mark the call as spam and block the call from future attempts. This information is then reported to the database, crowd-sourcing what numbers are unwanted calls. The app then blocks unwanted calls for all users of the app. Brilliant right?

Well, not so fast. Americollect has been tracking our numbers in this database along with our early out client’s numbers, and the scary challenge is that legitimate numbers are being marked as spam. Imagine if all numbers you own are one day blocked from appointment reminders, pre-surgery authorization calls, calls from your doctors to relay test results, or in our case calls to try to communicate about patients’ balances. The lost revenue in missed appointments alone should be scary to any healthcare system.

So what to do?

1. Assign an individual to continually check the FCC’s database to ensure your telephone number is not reported to this database. If your number happens to be one that is blocked, the FCC does allow for you to report that your number is a legitimate business.
2. Download as many of the apps as possible and double check to see if your numbers are being blocked by calling your cell phone.
3. Start gathering emails NOW!
4. Request the ability to text your patients.
5. Ask for as many phone numbers as you possibly can.

If you have any questions regarding this article, please contact Shawn@americollect.com.

 

 

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A Tale of Two Early Outs

Nick McLaughlin,
Ridiculously Nice Sales and Business Development

It was the best of plans, it was the worst of plans, it was the age of rising deductibles, it was the age of shrinking budgets, it was the epoch… I had to look up what the word “epoch” meant, so I’ll stop there! Shout out to Charles Dickens for letting me play on his epic opening of A Tale of Two Cities to begin this article on how I’ve seen Early Out Collection Services work brilliantly to improve the patient experience for hospitals and health systems, reduce A/R Days, and accelerate cash flow, and how I’ve seen it turn into a total nightmare if the program is not set up properly, or the wrong partner is hired. If you’d like to skip the rest of this article, here’s the best advice I have to give: do everything you can to simplify your patients’ experience with your billing process. That focus will send you down a successful path.

The Story

Hospitals and health systems have been going down the path of “do more with less” for a long time now, and one result of that is that resources have been focused on higher yield activities like insurance claim follow up, rather than collecting self-pay balances. Now that the average annual deductible for a family health insurance plan is over $8,000, patients are paying much closer attention to their medical bills. This results in many more patient calls with questions on their bills, financial assistance availability, and options for payment. When this increased demand for customer service attention meets a shortage of in-house talent able to answer patient questions, hold times and call abandonment rates increase to unacceptable levels, patients get frustrated, and the experience the patient just had with your facility can get spoiled no matter how wonderful their care. Not to mention that with growing deductibles comes an increased risk of revenue leakage. We know that the longer an account goes unpaid, the less likely we are to collect it, so adequate follow up is more important now than ever.

That’s where an Early Out partner can come in and be a big help in handling those inbound call questions, keeping hold times low, following up on unpaid accounts in a timely manner, and streamlining communication and account resolution for patients. That said, there is a lot at stake with an Early Out partnership, especially since the company you hire represents your hospital(s) directly, so be careful to avoid these pitfalls we have run into that compromise the patient experience, and result in way too much time spent with unhappy patients.

Early Out Pitfall #1 – “Day 45”

One way to set up an Early Out partnership is to place accounts with that company 45 days after the first bill goes out. The first bill has the phone number of the hospital’s business office on it, but the subsequent bills sent out by the Early Out partner often look very different and have the phone number for their office, not the hospital. The biggest problem with this arrangement is that a patient can have an account with the Early Out company, and another bill still at the hospital, and would have to speak with two different business offices to resolve both balances, even though both places said they were the business office of the same hospital.

To avoid this issue, place all self-pay balances with your early out partner the day the accounts drop to self-pay. We also highly recommend that all statements sent to patients come from the same statement vendor, whether that’s the one you currently have in place, or the one the Early Out partner uses. That way they look like bills the patient has received before and they don’t think they may be receiving a scam attempt.

Early Out Pitfall #2 – Multiple Early Out Partners

Most hospitals across the country use multiple partners for bad debt collections in order to compare performance and have a backup plan if one of the agencies starts falling behind. When it comes to Early Out, those benefits need to be weighed against the benefits of presenting a unified business office experience to your patients. Many households these days have multiple last names due to an increased number of blended families and changes in societal norms. If you have two partners for early out, and accounts are alpha split by last name, a good number of your patients could have to talk with one Early Out partner for one family member’s accounts, and another Early Out partner for another family member’s accounts; a huge source of patient dissatisfaction.

We highly recommend only using one Early Out partner. In order to manage performance, I encourage you to hold them to call center customer service metrics such as call abandonment rate (under 5%) and percentage of calls that wait less than 30 seconds before being answered (70% or higher), as well as monitoring a monthly activity report of inbound calls received, outbound calls made, statements sent (if applicable), and of course, dollars collected.

The moral of the story is this, avoid these two common pitfalls by simplifying the patient experience with your business office, and you’ll be rewarded by happy patients, higher collections, and higher patient loyalty for years to come. Make it as easy as possible for them to get answers to their questions and resolve their self-pay balances, and good things happen. From the patient’s perspective, paying for healthcare services is already a very stressful experience. Help them help you strengthen your bottom line by devoting the thought and resources required to offer an awesome patient experience!

 

 

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Question and Answers

We have created a new section in our newsletter to share our questions and answers from our clients or questions we ask of our peer-network for our clients. We hope you find these as helpful! These questions have been shortened and removed de-identified.

Question 1: “I have a question in regards to 501r and the requirement of not asking for payment of prior balances at the time of registration and advice”

Answer 1: The trick comes down to determining “emergency or medically necessary”.

Here are the three ways that I know people are asking for money:

1. Some registration areas you may be able to classify as “non-emergency or medically necessary” with a policy to allow them to request money on past balance.
2. I have heard some facilities are asking the question “is this appointment an emergency, medically necessary, preventive, or just an illness” and if the patient answers is “no” they document, then they ask for the past due balances.
3. Finally, you can ask for money on past due balances if you immediately offer financial assistance application and offer to help them fill it out.

Question 2:
“I have a question on returned mail as it relates to the 501r requirements for ECAs. It has come up recently that a statement was returned. Currently we have Epic workflow to immediately send to bad debt approval Work-queue.

Per our policy, we have language regarding the guarantor’s responsibility of providing the correct mailing address but don’t specifically refer to it as returned mail as the indicator that we don’t have a correct mailing address. Do you think we are ok to send the accounts to collections upon the first returned mail (per our policy) assuming it is past the 120 days from the first post-discharge statement?”

Background: Americollect has recommended adding, (It is the patient’s obligation to provide a correct mailing address at the time of service or upon moving. If an account does not have a valid address, the determination for “Reasonable Effort” will have been made.) to the billing and collection policy to address statements and final notices that are mail returns.

Answer 2: Yes.
1. You are following your policy.
2. Americollect has built controls in place to ensure that we wouldn’t do ECA (specifically credit bureau reporting) until 120 days after the first statement. We do this by using the Epic data file and extracting the date of patient responsibility, date of last payment, or date of service and correctly add the additional number of days to each one of those accordingly.

Question 3: XYZ Health is also looking at using our collection prediction score to cancel accounts off as presumptively eligible for financial assistance. The question is when to presumptively qualify. Their controller is having issue with writing off the account as bad debt (accounting wise) and then reversing from bad debt and then applying financial assistance to rebuckets for accounting.

Would you mind sharing if you actually reverse the bad debt accounting bucket and then reapply as financial assistance accounting wise. And then a follow-up, what do you do when the “books” have closed for a year?

Answer 3:
Yes, we do just that! The account is originally written off to bad debt. Upon reclassification (per policy definition), the account has a negative transaction posts to bad debt and the balance is moved to charity care on the general ledger. These are not prior period adjustments. They are run through current period as the change is based on current information that was not known at the time of the write off (and in some cases, circumstances have changed, such as the guarantor is deceased).

Here was the background provided as part of a memo/documentation to our controller for our change in policy in 2013. Whether the accounts are processed through the revenue cycle system or just as a general ledger transfer would depend on the age of the accounts.

————————————————————————————————–
HFMA Guidance:
Bad debt results from the unwillingness of a patient to pay, whereas charity service is provided to a patient with demonstrated inability to pay. HFMA’s P&P Board Statement 15, Section 4.1 advises that “in some cases, [charity] eligibility is readily apparent, while in other cases, investigation is required to determine eligibility, particularly when the patient has limited ability or willingness to provide needed information.” [Emphasis added]

In cases where the patient never requests financial assistance, or is unwilling/unable to provide the needed financial information, the account defaults to bad debt. However, section 4.3 of the P&P Board Statement states, “Commencement of collection efforts does not alter the patient’s financial status. A provider’s collection efforts, including the use of outside collection agencies, are part of the information collection process and can appropriately result in identification of eligibility for charity care.” [Emphasis added]

Do you need advice or have advice on these topics? Write us at shawn@americollect.com and we will share.

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