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Shawn Gretz Appointed to HFMA National Advisory Council Revenue Cycle Committee

Shawn Gretz, President of Americollect, has been appointed to the Healthcare Financial Management Association (HFMA) National Advisory Council (NAC) Revenue Cycle Committee beginning June 1, 2020. In his two-year appointment, Shawn will join the 23 members of the NAC to focus on key issues facing the healthcare industry and HFMA.

Shawn has been an HFMA volunteer since 2006 in various roles and capacities, including president of the Wisconsin chapter and a member of the Regional Executive team for Region 7 (Illinois, Wisconsin and Indiana). During this time, he has had many accomplishments, and his dedication to HFMA has led to his appointment to the NAC Revenue Cycle Committee.

“I’m excited to join the NAC Revenue Cycle Committee to learn about the pain points that are impacting the industry from a revenue cycle standpoint,” said Shawn. “I look forward to bringing my experience from ridiculously nice self-pay and bad debt collections to the committee to help improve the patient experience in healthcare.”

The NAC provides professional perspective on thought leadership topics important to HFMA members. Council appointments are made from individuals who are active in their profession as well as HFMA volunteers who are knowledgeable in their respective areas.

Americollect firmly believes that everyone deserves to be treated Ridiculously Nice, all the time, no matter what. Collecting only for the healthcare industry, we utilize our Ridiculously Nice approach to open communication lines and build trust with the patient, providing the same compassionate approach that they expect from their healthcare organizations. We partner with over 130 hospitals and health systems and over 7,000 physicians to collect more money than our competition while creating an unparalleled patient experience.  

 

 

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Can you wait to be paid?

It would be pretty sweet to be able to buy a new car and not pay for it, right? Or to just walk in and buy groceries without opening your wallet. But how long would the auto manufacturers or grocery stores stay in business if they had to wait years to get paid? Not very long. But that’s exactly what is happening in the healthcare industry.

It seems like every few years someone in congress decides to “help” protect consumers against rising medical costs. Sure, they mean well, but Rep. Rashida Tlaib, a Democrat from Michigan, doesn’t understand the ripple effect a bill like H.R. 5330 would have.

H.R. 5330, also known as the Consumer Protection for Medical Debt Collections Act, is a bill “to amend the Fair Debt Collection Practices Act to provide a timetable for verification of medical debt and to increase the efficiency of credit markets with more perfect information, to prohibit consumer reporting agencies from issuing consumer reports containing information about debts related to medically necessary procedure, about and for other purposes.”

But what does that really mean? It means that consumers would have up to TWO YEARS before it impacts their credit, an extremely long time compared to what is currently allowed. Plus, the legislation would delay the ability to report medical debt to credit reporting agencies for one year, and it would ban the reporting of debt arising out of “medically necessary procedures,” which would be the majority of accounts sent to collections.

And while some believe this would help consumers, it would just kick the can a little further down the road. Consumers have several options when it comes to dealing with their medical expenses – including charity care – and agencies are often the ones to educate them on these choices. If Congress takes away our ability to communicate with consumers in a timely manner, it only pushes that obligation off and adds to an uncertain financial future with a smaller window for resolution, and even less chance of recovery.

Join us in letting our U.S. Representatives know how this would impact the entire healthcare world by calling or emailing your Representative TODAY.

 

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It’s My Birthday and All I Got Was This Surprise Medical Bill

Nick Mclaughlin, Ridiculously Nice Sales

Yes indeed, it was my birthday this week! I didn’t actually receive a surprise medical bill for my birthday (thank goodness!), but there sure is a lot of buzz on the topic in Washington D.C.! With the increase in high-deductible health plans in America, patients are feeling the financial impact of their healthcare services more directly than ever.

What exactly is a “surprise medical bill,” and why is it a problem?
Proposed surprise medical bill legislation specifically addresses the conundrum of in-network and out-of-network healthcare providers. For example, if you visit the Emergency Department of a hospital that is in your insurance plan’s network, yet the physicians group that staffs the ED is out-of-network, the patient would receive a surprise medical bill. Many hospitals use out-of-network consulting services such as radiology and pathology. If a patient utilizes a hospital with outsourced services, they could end up receiving a surprise medical bill, even though the hospital they visited was in-network. Another such situation resulting in a surprise medical bill would be using an out-of-network ambulance, regardless if it is air or ground transportation.Situations such as these, along with the increase in high-deductible health plans, results in a rise in liens on homes, bank accounts and taxes, garnished wages, and crippling medical debt. The Kaiser Family Foundation completed a national poll of partisans, asking whether or not the federal government should protect patients from balance billing for out-of-network services. The results of this poll shows that 90% of Democrats, 77% of Independents and even 61% of Republicans said “Yes.”

A new bipartisan proposal would remove patients from disputes between insurance companies, doctors and hospitals. This act would require that health insurers pay at least the median in-network market rate for the area. For bills that are above $750, either side could seek to have an independent arbitrator resolve the conflict if they disagree with the benchmark rate. This act is the marriage of the first two solutions below.

Possible Solution Number #1 – Regulate Out-Of-Network Payment (“Burn in Hell”)
The first possible solution to reducing surprise medical bills comes out of the Senate. Senators Bill Cassidy (R-LA) and Maggie Hassan (D-NH) offer a two-fold proposal: step one – prohibit balance billing, and step two – regulate out-of-network payment. The plan seems relatively simple at first glance, but big questions remain about how prices would be set. Would the payment standard be a percentage of Medicare reimbursement? Or a percentage of average in-network payments?

This is similar to a plan some health plans are enacting called “reference-based pricing.” It’s a simpler solution compared to others that have been proposed, but it significantly reduces the ability for providers and insurance companies to negotiate contracted rates. A large health system in North Carolina decided not to participate in such a health plan that capped provider payments at 160% of the Medicare rate for inpatient care and 230% of the Medicare rate for outpatient services. An administrator from the system sent an email to the health plan that read, “Burn in hell, you sorry SOBs,” further stating that the plan “would financially destroy every hospital in this state.” Mandating a program like this for out-of-network payment would likely distort some of the market forces left in healthcare.

Possible Solution Number #2 – Baseball-Style Arbitration
The second possible solution to reduce out-of-network pricing comes out of the House. Representatives Frank Pallone (D-NJ) and Greg Walden (R-OR) offer a similar restriction against balance billing, but include baseball-style arbitration for determining what the payment should be. In Major League Baseball, most young players with less than three years of major league “service time” earn the league minimum salary. However, once they reach three years, they become eligible for salary arbitration. The team submits a salary offer, the player submits a salary offer, and a third-party arbiter decides which salary is the fairest; no compromise.

Balance billing patients would still be prohibited, but arbitration would not be between the patient and the provider each time a service is rendered, but instead with the insurance company and provider for a set period. The biggest questions around this solution are who would set the guidelines for arbiters, and what should those guidelines be? It does maintain market forces to an extent, but administratively, a system like this is very burdensome.

Non-Legislative Possible Solution – In-Network Matching Guarantee
Another possibility is for hospitals to voluntarily offer an in-network matching guarantee. This means that any doctor or clinician who treats a patient at an in-network hospital would have to accept the patient’s in-network payment rate. It seems like a nice way for hospitals to differentiate themselves from neighboring hospitals to increase market share, but could discourage physician groups to practice at their hospitals.

Who Wants What?
Once again, the money fight in healthcare is between insurers, hospitals and clinicians. Insurers want federal payment standards to be set, which would likely lower reimbursement benchmarks for setting contracted prices. Providers, for the most part, prefer the arbitration style approach to settling payment disputes, since it would make the process to challenge their out-of-network rates more difficult. Limiting out-of-network payment rates could significantly distort the importance of contracting between insurers and providers. A hospital threatening to leave an insurer’s network gives them leverage to negotiate higher payment rates, and an insurer threatening to leave a provider out of their network gives insurers more leverage to negotiate lower payment rates. How surprise medical bill legislation impacts this dynamic will be interesting to follow in the coming years. We will continue to keep an eye on this issue to see where it goes.

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501r Questions and Answers

Shawn Gretz, President

Our charity program offers a partial discount or full write-off based on the current Federal Poverty Guidelines. If a patient is approved for partial charity, are we required to reactivate the account (cancel with the agency) and restart the billing cycle based on the new balance?

Not necessarily, but you do have to send an approval letter with a 30-day notification to pay the remaining account balance in full before collection actions can begin again.

When a patient applies for financial assistance and the account has already been submitted to our outside collection agency, does 501(r) require us to retract the account from the agency while the account is pending review for financial assistance?

No. You do not need to retract the account but you should notify the collection agency and ask them to put the account on hold. For instance with Epic, we normally use billing indicators to automatically notify us of accounts that are put in financial assistance work queues. If approved, we receive a different billing indicator notifying us of approval and we wait for the balance change in the adjustment/withdrawal file. If denied, we normally get a different billing indicator. Unless your policy reads differently, then you will have to retract while pending.

Our current process is that once notified of the passing of the patient, the spouse will then become responsible for the outstanding balance and our communication is targeted toward the spouse and collection processes. When we make the spouse become responsible for the charges, per 501(r) rules, do we need to reset the aging to allow for 120 days to pass before sending to collections?     

I would suggest you define who the “responsible party” is in the financial assistance policy. By defining who is in the billing and collection policy, it will allow the “reasonable efforts” period to continue without starting over. For example, a responsible party is defined as all individuals who live together, married, and/or by state law, are required to pay for services regardless of whose name is used for initial correspondence.

We bill some outpatient (retail) pharmacy. Is this a required charge to be eligible for charity care and to refund if qualified, under 501 regulations? If we do include it, would we need to follow 501(r) guidelines and refund any amount going back 240 days including these charges if the patient already paid?

Yes, you can exclude this and many do. The IRS allows you to exclude any services you wish, but this requires an update of your policy. This is especially the case if the pharmacy falls under the same Tax ID or reports up to the same financials of the 501(c)(3) hospital or health system.

Does a physician list that includes generic practice names such as Chiropractor, Orthodontics, Dentist, Plastic Surgery, and Optometry meet the 501(r) requirements?             

Technically, no, this doesn’t meet the requirements. In a follow-up to the final regulations, the IRS specified that the actual names of the physician practices like “XYZ Radiologists. LTD” should be spelled out. Also, a hospital facility should update its list of providers by adding new or missing information, correcting erroneous information, and deleting obsolete information at least quarterly. Make sure you take reasonable steps to ensure that the list is accurate. The good news is if you forgot about this, it is considered a minor mistake that doesn’t have to be reported, just corrected.

Right now we have a financial assistance policy posted for each of our affiliates/critical access hospitals.  The intent is that each of the policies are the same as our master policy.  Is there any reason that we need a separate policy for each one?  Can we just indicate in the master policy which locations it applies to and then have a separate board approval page for each location attached to the policy?

Yes, you can have one master agreement for all hospitals in a health system. The only stipulation is that you need to use the most generous AGB for all hospitals. Finally, the final regulation allows the board to specify an individual or committee to approve the financial assistance policies on behalf of the hospital. Because the ability to have all hospital boards approving the same policy is cumbersome, I would suggest instead to create a committee assigned by the board at each hospital to take up approval processes and relieve some of the additional work of the board. This will also make it easier on the Revenue Cycle team!

Does the 501(r) Compliance apply to clinic and hospital services?

Yes and No.

1. It depends upon the tax reporting of the hospital. If the clinic is its own entity and doesn’t report up through the hospital financials, then it could be considered a disregarded entity and the answer would be no. If the clinic reports up through the hospital’s financials then the answer is yes. Check with your CFO or

Controller to make sure.

2. You could always just add the clinic as part of your exclusion lists in your financial assistance policy and then the answer is No.

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Price Transparency Turbo Booster – Are You Ready?

Nick McLaughlin

Regional Director of Ridiculously Nice Sales at Americollect

As the rule stands today, hospitals are required to provide patients with a list of their standard charges at the patient’s request. This nudge toward healthcare consumerism and price transparency opened the age of patient responsibility estimates, but has not achieved the level of “shopping” for lower cost healthcare services that CMS wanted to see. Enter the price transparency turbo booster – 2019 IPPS/LTCH PPS final rule. Starting January 1, 2019, all hospitals will be required to post that same list of standard charges on the Internet in a machine-readable format.

Patient Challenges According to the CMS FAQs regarding this issue, the requirement applies to all items and all services provided by the hospital. One of the biggest challenges regarding this issue is that the list is to be pulled from the retail chargemaster, which does not reflect the amounts hospitals are actually reimbursed for their services. The published prices will be even further from the amounts patients should expect to pay out of pocket. Hopefully this possible confusion about how much a service will actually cost patients won’t cause them to postpone care and allow health issues to get worse.

Potential Hospital Solutions I see more vendors each year offering patient responsibility estimates, and if that isn’t something that your hospital has decided to implement, now may well be the time. One of the best responses to someone calling in to complain about how high your prices that they found on the Internet would be, “Well, Nick, what is the service that you are looking for?” How much a service is going to cost them is far more important to them than arguing that your retail chargemaster prices seem higher than your neighboring hospitals’. Teaching your front line staff to have these conversations in a Ridiculously Nice way, in order to help patients get the information that they are truly looking for, will pay great dividends with patient loyalty in the future.

Are you ready?

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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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