Friday,
August 29, 2003
Vol. 6, No. 69
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On Complianceinfo.com
Sample compliance policies and procedures. (For subscribers to Strategies for Health Care Compliance only)
Sample audit programs. (For subscribers to Health Care Auditing Strategies only)
The OIG Work Plan for Fiscal Year 2003
Ask the Expert
Compliance Hot Topics: Billing and Coding, EMTALA, Stark, HIPAA
Question of the Week
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Welcome to Compliance Monitor Q&A!
Our mission is to answer your difficult compliance questions—and your simple ones, too. To submit a question, send it to Compliance Monitor Q & A editor Melissa Osborn at mosborn@hcpro.com.
We hope you enjoy this service and we welcome your feedback.
This week's questions
Pay-per-view article
Quick survey
Questions and Answers
Can we require uninsured patients to pay up front?
Q:
My multi-specialty clinic has lost revenue from uninsured patients who do not pay their bill. I want to write a policy that says all uninsured patients must pay up front for their visit or at least give $50. Is this legal in most states? Does this policy need to state that we will only "urgent care" patients without insurance?
A:
Developing a financial policy for your multi-specialty clinic is a sound business decision. However, you should develop the policy for all patients, not just uninsured ones. Otherwise, your clinic may appear to be discriminating against certain groups.
Your financial policy should provide guidance to patients on how your organization will handle the following:
Collect co-pays and past-due balances
Create financial arrangements for unpaid balances
Provide charity care or use a sliding scale for patients with low incomes
Handle payments for services not covered by the patient's insurance
Collect prepayment for services
Accept cash, checks, money orders, and credit cards
Apply special circumstances for automobile accidents and non-assigned insurance
Ask patients to sign the financial policy, then give them a copy and keep the original in the medical record so you have proof the patient received the it.
Clinics are within their legal rights to expect patients to pay for services, whether through insurance or self-pay options. Clinics may postpone or terminate care, with the understanding that patients must follow certain rules and regulations. Based on a clinic's location, it should contact the state medical society or board of medical examiners to determine whether there are any state provisions for postponing or terminating care. Keep a copy of the Fair Debt Collections Act and the Fair Credit Reporting Act for reference.
Clinics must follow different requirements for terminating care than for postponing care. You cannot, for example, terminate patients following a major medical event, unless the patient's care is stable or the patient is receiving medical care from another physician. Take care of patients who need urgent care or refer the patient to the nearest hospital emergency room. Define "urgent care" in your policy so physicians and staff understand this clearly.
This question was answered by Michael O'Connell, MHA, CMPE, CHE, senior director of the Cleveland Health Network MSO, LLC, in Independence, OH.
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Tell us about your financial policies!
Click here to take our quick survey on your financial policies and procedures!
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JOIN THE COMPLIANCE MONITOR TEAM!
Are you a compliance expert? We're looking for compliance experts in coding, billing, documentation, HIPAA, EMTALA, Stark, laboratories, and many other areas of compliance. If you are interested in answering questions from your peers, please e-mail Compliance Monitor editor Melissa Osborn.
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Pay-Per-View article:
Clinical trials: 10 easy steps to assess your risk
Auditing and monitoring clinical trials is a must for any organization that performs clinical research. Since human subjects participate in this research, it is critical to have systems in place to prevent errors and omissions, says Lisa Murtha, JD, vice president of audit and compliance at Children's Hospital of Philadelphia.
The government is actively pursuing research organizations for compliance violations, says Murtha. The media are also spotlighting ethics concerns. With stakes this high, help your organization put a top-notch auditing and monitoring plan in place . . .
To find out how to audit clinical trials, order the pay-per-view article "Clinical trials: 10 easy steps to assess your risk." The cost is $10. Subscribers to the online version of Health Care Auditing Strategies have free access to this article. Subscribers to the print edition can find it in their August issues.
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You can read this article-and much more-in the August issue of Health Care Auditing Strategies. Your cost: Five stories for only $30! You'll also learn how to audit observation services, how to perform a marketing audit, how to assess your clinical trials, and how to use aggressive mammography audits to boost detection and cancer analysis.
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Click here to learn more or order your copy today for only $79! Or, if you'd prefer, call 800/650-6787 and mention Source Code EB22518B. Your order is risk-free.
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Can we charge patients for administrative costs?
Q:
Can I collect service fees from patients for items such as medical file management, medical billing services, phone consultations, and other overhead services?
A: To read the answer to this question, click here.
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Quick survey:
Does your organization train employees on Medicaid compliance issues?
To submit your answer, go to the Question of the Week at
Complianceinfo.com.
Here are the answers to the last survey:
When will your organization begin auditing its HIPAA compliance program?
- Within the next six months: 68%
- In 7-12 months: 17%
- In 12+ months: 9%
- We do not plan to audit: 6%
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Network with your audit colleagues
"Audit Talk" is a new, moderated chat forum that members can use to post messages or questions for their peers 24-hours-a-day. "Audit Talk" offers a free forum to network, share ideas, and solve problems for those in the audit industry. Getting involved is easy. To subscribe, just send your request to this e-mail: owner-audit_talk@hcpro.com.
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e-mail newsletter, so why not pass on this resource to your peers? Sign up a colleague and get $20 off your next purchase on HCPro's Healthcare Marketplace!
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Send your comments and questions about Compliance Monitor Q&A to:
Melissa Osborn
Managing Editor
mosborn@hcpro.com
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