Quicker Wins for Early
Out Healthcare Receivables
December 16th, 2014
Patient Payment Collections in the Age of the ACA
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This information is not intended to be legal advice
and may not be used as legal advice. Legal advice
must be tailored to the specific circumstances of
each case. Every effort has been made to assure this
information is up-to-date. It is not intended to be a
full and exhaustive explanation of the law in any
area, however, nor should it be used to replace the
advice of your own legal counsel.
Legal Disclaimer
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Agenda
Introduce Panelists
Outlook: Collecting Medical Debt under ACA
Primer: 501(r) Compliance and Collections
Medical Collections Best Practices
Collections and FSA/HSA Payment Processing
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Panelists
Pam Kirchner, CEO
- BCA Financial Services
Dave Yohe, Director of Marketing
- BillingTree
Will Stagl, Moderator
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Introductions
Pam Kirchner, CEO
– BCA Financial Services
Under Ms. Kirchner’s leadership BCA Financial Services, Inc. has become a well known industry leader in accounts receivable management solutions. As Chairman of the Board, President and CEO she provides leadership and direction toward the achievement of the organization’s philosophy, mission, strategy, and its annual goals and objectives. She plans and directs all aspects of the firm’s marketing and sales policies, objectives, and initiatives as well as manages a team of internal and external customer service representatives ensuring the firm is constantly and consistently exceeding customer’s expectations. Ms. Kirchner has been employed in the collection industry for thirty-five years, has extensive knowledge and experience in healthcare collections and has provided consulting services to numerous healthcare organizations throughout her career. She currently serves on the Medical Debt Task Force, the ACA International Council of Delegates, participates on the ACA Committee of 100 and is a Director and past President of the Florida Collector’s Association.
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Introductions
Dave Yohe, Director of Marketing
– BillingTree
With over 24 years experience in marketing and advertising, Dave Yohe heads up BillingTree's corporate marketing team. Responsibilities include marketing, lead generation, advertising, tradeshows, public relations, marcom and branding. Additional focus is spent on analyst relations and new market penetration. Dave joined BillingTree in February 2010 after a multi-year leadership role with online fraud detection and prevention firm, the 41st Parameter. Dave has also successfully led marketing teams for Infusionsoft and JDA Software, gaining over 13 years of software technology marketing experience within the financial services, retail, e-commerce and CRM verticals.
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Panel Discussion
Client Perspective
Legal Perspective
Patient Perspective
ARM
Perspective
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ACA Impacts
How will the ACA affect the business of the
Healthcare provider?
How will the patient experience change? How
will policy complexity impact collections?
How might it impact their collections partners?
Transaction volumes and balance trends
What critical skills/expertise must ARMs bring to
the table?
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Audience Poll
Which services do you offer as an agency to
your clients?
Web portal
IVR
Agent-assisted phone
All of the above
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• Section 501(r) currently is in effect. The IRS states that
tax-exempt hospitals must have “a written financial
assistance policy which includes … measures to widely
publicize the policy within the community to be served
by the organization.”
• The IRS notes that taxpayers may rely on the proposed
regulations for Section 501(r)(4) through 501(r)(6) until
final or temporary regulations are issued.
501(r): Financial Assistance and Billing/
Collections
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• Have a Financial Assistance Policy (FAP) as part
of your credit and collection policy
• Signage and handouts that discuss your FAP
• Provide FAP upon discharge
501(r): Financial Assistance Policies (FAP)
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501(r): Extraordinary Collection Activities (ECAs)
• Hospital Organizations are responsible for any actions taken
by their third-party vendors in violation of Code Sections
501(r)(5) and 501(r)(6).
– Do Not engage in any Extraordinary Collection
Activities (ECAs) for 120 days after patient
responsibility begins.
– Send out a notice 30 days before any ECA occurs
outlining that without payment in full, a payment plan or
FAP application, what ECAs you (or your collection agency)
might engage in to collect this bill.
– Send out three notices for each service date.
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501(r): FAP Processing and Notification
• In the event of a processed application, send a written notice which details how their eligibility was determined and why they qualified (or did not) for the level to be awarded.
• In the event of a favorable determination, refund the patient any amounts which exceed the balance they would have owed after FA adjustment had they not made a payment.
• After the 120 days notification period, automatically allow an
additional 120 day application period.
– If during this subsequent period, the patient applies for FA, all ECAs must be abandoned until the application is processed and eligibility has been determined.
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501(r): FA Policy Communication
• Include a summary of your FA policies with all billing notices and statements.
• Discuss your FA policy in every call with patients
regarding their services and accounts.
– It appears this will apply to all calls, though nothing is required until the rule is finalized.
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501(r) and Early Out
How does 501(r) affect early out?
How does it affect bad debt?
How does the financial assistance process impact
collections?
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Medical Collections Best Practices
Why is reconciliation between providers and agencies
becoming more critical?
What responsibilities do agencies share for reporting and
tracking consumer complaints under FDCPA?
How important will compliance become as an issue to
providers? How will it impact vendor selection?
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Audience Poll
Do you offer your clients the ability to pay with
an HSA/FSA Account?
Yes
No-but we would like to
No-not interested
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Collections & FSA/HSA Payment Processing
HealthPas Gateway
ARM Underwriting
HealthPas Gateway +
Underwriting
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BillingTree HealthPas Solutions
Resolves security and payment processing issues for
Agencies collecting HSA/Flex payments on behalf of the
provider.
No more… › Manually collecting payment info to be passed on to the provider
› Logging into client PAS to run payments
› Logging into the provider’s patient Web portal for payments
› PCI Compliance violation concerns tied to card data being stored and
passed via Excel or other file formats.
› Conflicting reconciliations due to declined transactions at the provider
› No more re-works (eliminates calling back patients for payments that
declined)
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HealthPas Gateway
1 • Agency requests provider’s Merchant ID (MID) and
supplies to BillingTree
2 • BillingTree configures and validates client MID
compatibility with Gateway
3 • Agency is enabled to collect credit/debit/FSA
payments using client MID via the BillingTree gateway
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HealthPas Underwriting
Gateway + Provider Underwriting
Transaction visibility all the way through the payment process
Billing/Deposit control
Agency could earn monthly recurring revenue on new accounts
opened at BillingTree for their providers.
Gateway + Early Out Agency Underwriting
› EO Agency may collect/process HSA/Flex payments for multiple
providers
› Separate EIN #s
› Deposits go directly to the Agency
› In writing, has to show it is for 1st party services & EO only, one
account for each provider
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Contact Info:
We are happy to assist you with any further questions
you might have regarding how to select the correct
payment solution for your needs –
Thank You