Rehab

Update collections policies in 2005

Rehab Regs, February 1, 2005

Don't let copays and deductibles fall through the cracks

If one of your New Year's resolutions is to become a financial dynamo at your rehab facility, updating your collections policies is a good place to start. Doing so will not only increase your bottom line, but it will also keep the feds off your back.

Proper collections procedures require adequate communication between you, your patients, and your payers. You need to understand what services Medicare or a third-party payer will cover, and your patients must understand what amount they will be responsible for paying.

"The process has become so complex for providers that you can only imagine how confusing it is for some patients," says Lynn Steffes, PT, president of Steffes & Associates, a consulting firm in New Berlin, WI.

The most important steps to creating an effective collections policy is to have it in writing and to make sure your facility's staff comply with it, says Tessa Chenaille, CHC, president and chief executive officer of Chenaille Compliance Consulting, LLC, in Medford, MA. It may seem elementary, but master those two steps and you're well on your way to a rosy financial future.

Collections tips

The following are some components of a successful collections policy. Compare them to the policy you already have in place, or use them to help you create a new one for your facility:

  • Attempt to collect all copays and deductibles. Routine waiving of these fees is a violation of the anti-kickback statute, says Chenaille. You can waive copays and deductibles under special circumstances if you have a clear policy that specifies when and under what circumstances they may be waived. Look at each waiver on an individual basis, says Chenaille.

  • Make good on any promise to send a patient's information to a collection agency. The Fair Debt Collection Practices Act states that a debt collector may not use any false, deceptive, or misleading information to collect a debt.

  • "Don't use it as a threat if you don't intend to turn the balance over to a collections agent," says Chenaille. "If you say you're going to do it, make sure you actually do."

  • Include indigent guidelines or a financial hardship policy. Patients can usually qualify as indigent if they are on Medicaid, have a letter from a social worker supporting their indigent status, or fall at or below 200% of the federal poverty level.

  • To establish these specific guidelines, your facility must determine how much information it has the time and the staff to collect. For example, to establish indigency using federal guidelines, you must request tax returns from patients.

    Visit http://aspe.hhs.gov/poverty/04poverty.shtml to view the federal poverty guidelines.

  • Be consistent. If you offer preferential treatment to some individuals, you must offer it to all. For example, if you offer a payment plan to one patient with a high copay or deductible, make it available for all patients. Similarly, if you have a policy of sending out three demand bills and then turning the case over to a collections policy, do so for all patients who refuse to pay.

  • Payment pointers

    To make collections a less painful process at your facility, Steffes offers the following helpful hints:

  • Do your homework. Before patients even visit your facility, verify their eligibility for services and prequalify for their therapy. You'll know what the patients' plan cover and be able to adequately explain available coverage for any services.

  • Explain benefits and responsibilities. When your patients come in for treatment, Steffes suggests that you give them a copy of the policy and also keep one in their chart.

  • During payment discussions, let patients know that the copays and deductibles are a requirement from their insurance company, not from your office. For example, rather than saying, "You owe us a $20 copay per visit," say, "We called your insurance carrier and they stated that your liability is $20 per visit."

    Throughout the patient/provider relationship, clearly explain the different roles played by the rehab facility and the payer. "PTs by nature try to rescue patients from the process," says Steffes.

    "Let patients know you will act as their advocate, but the contract is between them and their insurance company."

  • Collect copays at the time of service. This is the simplest way to ensure payment, which helps you avoid having to track down money later.

  • Simplify and humanize the billing process. If patients have issues with their payment, they will most likely deal with your billing office. When you give them a copy of your financial policy, include a business card for the biller who will work with them, says Steffes. Also, if that department has extended hours on certain days, let patients know so they can call to ask questions when it's most convenient.

  • Only send statements when patients owe money, and circle that amount. Finally, mail it in a hand-addressed envelope, which recipients are more likely to open, says Steffes.

    Policy upkeep

    Even if you're already on top of your collections policy, review it every year to ensure that it still meets your facility's needs. Update it as necessary, and review it annually to sign off on it, even if nothing has changed, says Chenaille.

    Your policy should contain some general regulations, which your state association may be able to help you compile. These policies may also be found as part of your compliance plan. They should include some general billing guidelines, such as not upcoding, collecting reimbursement only for services that were reasonable and necessary, and only billing for services that were performed, says Chenaille.

    Your facility should then specify further who is authorized to waive copays. Chenaille suggests having one high-level employee responsible for reviewing and approving the waiver of copays and deductibles.

    For more information, Steffes suggests going to www.patientfriendlybilling.org, organized by the nonprofit Patient Friendly Billing Project, which is designed to help providers create easy-to-use billing procedures.

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