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Maintaining Collections During a Pandemic

In late January the Coronavirus reached the United States, radically changing the trajectory of 2020 in ways we won’t soon forget. No area has experienced more disruption and uncertainty than healthcare. From shortages of personal protective equipment and ventilators to reductions in elective procedures, from expectations of additional strain on emergency services to unclear revenue outcomes with questions about collections during a pandemic, the concerns for healthcare providers right now seem endless.

Hospitals can expect to feel financial pressure from this pandemic on several fronts. First, according to Rhett Brown, Managing Director, Research Analyst at Lazard Asset Management, in an article in The Bond Buyer, patients will choose to forgo profitable elective procedures this year, and the resulting excess capacity may or may not be replaced with treatments for patients with Coronavirus. And those treatments will end up costing hospitals additional revenue. Health Leaders predicts that nearly all hospitals would lose an average of $2,800 per Covid-19 patient case if reimbursement rates are not increased from the currently proposed rate.

We are hearing these same concerns directly from our clients. One shared that they are already experiencing a 30-percent reduction in their daily census, and if it continues, they predict a 50-percent drop in revenue.

Costs for supplies are also on the rise due to shortages in both the normal supply chain as well as the Strategic National Stockpile. New York Governor Andrew Como shared that masks that normally cost around 85-cents each were now costing $7 when they could be found. He, like others, have called for the government to nationalize the medical supply chain to help hospitals afford much-needed supplies. Hospitals will also see a rise in personnel costs as additional cases of Coronavirus are diagnosed that require a higher level of care.

Price gougers are also appearing in the critical drug and medical supplies markets, trying to cash in on the pandemic. In recent weeks, investment bankers and others have pressed healthcare companies to consider ways that they can profit from the crisis. If allowed, that profit will come in the form of higher costs passed on to hospitals and patients.

Compounding these rising costs are stories of mass unemployment spreading across America faster than the disease. Prior to the passing of the CARES Act, Treasury Secretary Steven T. Mnuchin had claimed that the unemployment rate could reach as high as 20-percent if lawmakers did not take action. While these are eye-opening numbers, the flip side is that if this awful scenario comes to be, 80-percent of the US workforce will remain employed without a major income disruption.

With the challenges the Coronavirus is creating, the last thing healthcare providers have time to worry about is their revenue stream. But in these uncertain times it’s never been more important. With significant reductions in incoming revenue, some hospitals – especially those in rural and smaller community settings – could be forced to close their doors. Alan Morgan of the National Rural Health Association recently told Kaiser Health News that if short-term cash isn’t addressed, we’re going to see hundreds of rural hospitals close before this crisis ends.

Considering the ramifications of these factors, it’s imperative that hospitals continue to collect any and all revenue possible during the Coronavirus pandemic, including self-pay balances, but the key is to do it in the most patient-friendly way possible.

First and foremost, empathy is paramount to collecting success and sensitivity to those affected by Coronavirus is essential. The unknown can cause emotions to run high, and there’s no place for anything less than kind, understanding words and actions. When on a call, and a patient says that they are experiencing financial hardship due to the Coronavirus, it is best to thank them for their time, mention any financial assistance options they may have available, apologize and end the call.

Here are a few additional steps that we recommend your collections partners take to help minimize the impact health issues will have on your patients during the Coronavirus pandemic:

  • Flag Accounts – Add a notation to accounts that are suffering financially due to the Coronavirus in both your system and your collections partner(s) system. An example of this is Epic users adding a Billing Indicator to track the accounts and ensure that collection activities cease until the pandemic has subsided.
  • Credit Reporting – Have your collections partner(s) temporarily stop reporting to the credit bureaus. With so many other issues occurring surrounding this pandemic, it is not the right time to affect an individual’s credit. This will also ensure that Coronavirus-related charges do not accidentally get reported. We do not know what will happen with these charges in the future.
  • Legal Action/Garnishments – Have your collections partner(s) pause all legal action and wage garnishments. As with credit reporting, this is simply not the right time to pursue these types of actions.
  • Insurance Check – Reviewing, identifying and verifying that insurance was correctly applied to your patient’s accounts is another step you and your collections partners can take to help maximize your revenue. Some accounts may be payable but were not correctly covered by the insurance company. Having your collections partners help identify missing insurance and follow up on these accounts could lead to the insurance company paying, which is a major patient satisfier.
  • Explore All Avenues of Additional Reimbursement – Look for opportunities to apply for Cobra with patients who may have recently lost employment. Additionally, backdated Medicaid or disability will become a greater revenue source for hospitals.
  • Financial Assistance – More patients will qualify for financial assistance, so working to qualify these patients as efficiently as possible will be extremely beneficial. This includes Medicare patients who will also qualify for Medicare Bad Debt. 

We have to remember that while there will be some patients who are unable to pay their bills, many will still have the means to pay. These are the patients you will want your collections partners to focus on communicating with during these times. Additionally, it is important to keep your inbound communication options strong, making it easier for patients to reach out to you with any questions or payments.

Though the nation is in turmoil, it is important to ensure that letters and responses required by law are still sent to patients regarding disputes, payment plans or receipts in a timely manner. Stay on top of any changes on a national and state level to remain in compliance, even when dealing with Coronavirus fallout.

Here in Wisconsin, Governor Tony Evers enacted a “Safer at Home” order, which closes any non-essential business. Hospitals from across the state have shared with us why it is important for collection agencies to remain operational during the Coronavirus pandemic. One such letter said,

“With respect to the COVID-19 response, [collections] are a critical function to [our facility] and our patients.  Patients during this trying time will need assistance planning their financial future, and [our facility] needs to continue to utilize [collection] services to maintain adequate cashflow.” 

The truth is, the Coronavirus is going to impact hospitals for the foreseeable future. There are several topics you will want to discuss with your collections partner/agency now to ensure they are prepared to support you during the pandemic.

  • Remote Workforce – Validate that they have made provisions for their staff – especially collectors – to be able to work from home. Stay-at-home directives will quickly shut down call center-based collections, making it harder, if not impossible, for them to continue operations.
  • Technical Infrastructure – If your partner/agency says that they are prepared to have their collectors work from home, ask for information on their technical infrastructure. A remote workforce has drastically different needs than office-based staff, and their system may not be able to handle this change.
  • Essential Business Status – While many jobs can and will be done from home, there are responsibilities (printing, incoming/outgoing mail, payroll, etc.) that will have to be handled from the office. If your collections partner(s)/agency does not have “Essential Business” status, any shelter in place orders will stop them from working on-location.
  • Remote Training – Collections can be a high turnover industry, and with the uncertainty caused by the Coronavirus, there will be a need to add and replace collectors. Make sure your partner/agency has the ability to hire and onboard new employees remotely. If not, you may see a decrease in revenue due to a dwindling workforce.

Nobody knows exactly how the Coronavirus will impact our country in the long or short term, but your survival may depend on ensuring a consistent collections revenue stream. Please take the time to review your current partners and agencies to safeguard your employees and patients during these uncertain times.

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Proposed FPL Changes and the Impact to Financial Assistance

Proposed changes to the Federal Poverty Level (FPL)Joseph Maretti, Ridiculously Nice Sales

The Trump Administration has proposed updating the way in which the Federal Poverty Level (FPL) is measured. The formula that currently determines someone’s poverty level has been around since the Social Security Administration created Medicare in 1965. The way Americans have spent their disposable income, along with inflation, has changed considerably since then. One could argue that it’s time to adjust this formula to be more in line with today’s current inflation measures.


Today, the U.S. Census Bureau looks at the poverty threshold and factors in inflation to provide an update on how many Americans are living in poverty every year. The Department of Health and Human Services (DHHS) issues poverty guidelines based on the number of individuals for each household. For example, the poverty level for a household of four is an annual income of $25,750. To get the poverty level for larger families, simply add $4,420 for each additional person in the household. For smaller families, subtract $4,420 per person. Guidelines for Alaska and Hawaii are higher due to cost of living. DHHS then bases their poverty guidelines around this threshold to determine an individual’s eligibility for certain benefits. Under the current proposal, the Office of Management and Budget would adopt a lower rate of inflation to determine the poverty threshold. This means fewer people would qualify for certain benefits as the poverty threshold would rise more gradually over time.


How could this impact your facility?


Should this proposal go through, it could mean a significant number of individuals who currently qualify for the financial assistance benefit would no longer be eligible. To help paint a clearer picture, the Center on Budget and Policy Priorities (CBPP), a left-leaning think tank, released a report this month examining the 10-year impact of the proposal:

  • More than 250,000 seniors or people with disabilities could either lose their eligibility for Medicare Part D’s low-income subsidy program or receive less assistance from it.
  • More than 150,000 seniors or people with disabilities could lose assistance with their Medicare premiums.
  • More than 300,000 children could lose Medicaid and CHIP coverage.
  • More than 250,000 people could lose the coverage they gained through the Affordable Care Act’s Medicaid expansion.
  • More than 150,000 ACA exchange enrollees could lose some or all of their cost-sharing assistance.
  • Tens of thousands of ACA enrollees could lose their premium subsidies, along with millions who receive smaller subsidies.

According to the Congressional Budget Office (CBO), estimates indicate that the yearly cut across federal health coverage programs would total in the billions of dollars by the tenth year. The impact on program eligibility thresholds would roughly double between the tenth and twentieth year; should the policy go into effect.


In the event the administration is successful, it may be likely that alternative measures will be created to determine the poverty level for social programs at the State level, so as not to rely on the federal poverty line.


Many hospitals rely heavily on the revenue that is generated through these federal programs for their indigent patient population, so it’s important to keep this proposed legislation on your radar. Americollect will continue to monitor this situation as it unfolds and watch for any updates or changes to the proposed regulation.

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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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