Navigating Point of Service Collections: Emergency Room Regulations
- 1. Regulations in the Emergency Department and Beyond Navigating Point of Service Collections
- 2. Overview Status of ED Collections Regulatory Requirements ED Collection Best Practices
- 3. The further along the revenue cycle a patient moves, the more difficult and costly it becomes to collect payment. CosttoCollect Time Cost to Collect
- 4. Bad Debt 50% of a hospital’s bad debt comes from the hospital’s emergency department. EDs are the largest source of bad debt for hospitals.
- 5. ED visits reached an all-time high in 2009 with 136 million visits In 2011, 20.4% of adults visited an ED 15.7% of the population didn’t have insurance in 2011. Increasing Visits ED VISITS # OF PHYSICAL EDs
- 6. Revenue Potential 2009 ED point-of-service collections represent an opportunity to collect 1-3% more in net revenue
- 7. EMTALA Review 2009 Passed as part of COBRA in 1986 Requires hospitals with Eds to provide care to anyone who needs it regardless of ability to pay, legal status, or citizenship 1. The hospital must provide an appropriate medical screening exam to all patients who present and seek care. 2. If a patient presents an emergency medical condition, they must be stabilized 3. Patient transfer is only acceptable if a patient requests the transfer or a physician certifies that medical benefits or a transfer outweigh the risks. EMTLA Requirements to Ensure Patients with Emergent Conditions are Seen in the ED
- 8. EMTALA –Pre-Registration 2009 “Reasonable registration processes” can’t inhibit treatment, but can include: • Preliminary demographics like name, age, and gender to create an account • CAN include asking if they have insurance and what kind, as long as it doesn’t delay care
- 9. Patient Protections and ACA 2009 • June 22, 2012 – Dept. of Treasury published proposed regulations referred to as Additional Requirements for Charitable Hospitals • Impact 3/5 of national’s hospitals • Violating could mean loss of tax-exempt status
- 10. Patient Protections and ACA • Requirements to establish and disclose a Financial Assistance Policy • Limitation on Collection Actions • Limitation on Charges • Non-discriminatory Emergency Medical Care Policy A hospital’s emergency care policy must prohibit debt collection on activities in the ED
- 11. Medical Debt Responsibility Act 2009 First introduced in 2011 with a newer version re-introduced on March 1, 2012 Addresses medical debt affecting credit histories Underscores concerns of many patients seeking medical care • 73,000,000 working age adults in US have medical billing/debt issues • In 2010, 30,000,000 Americans were contacted by collection agencies regarding unpaid medical bills
- 12. Best Practices 2009 Bedside Registration Finalization of Financial Arrangements Consistent Collection Methodology Service Provider Partnerships Comply with EMTALA and HIPAA and collect patient liabilities at the appropriate time
- 13. 2009 1. Facilitates examining patients as quickly as possible 2. If patient’s information is not on file, registration begins at triage 3. Do not leave patients with the impression that their financial situation will have an impact on delivery of treatment. Bedside Registration Best Practices
- 14. 2009 1. Designate a “financial discharge” area of the ED where the clinician connects the patient with revenue cycle staff. 2. Ensure there is a private space for financial counseling to take place Finalization of Financial Arrangements Best Practices
- 15. 2009 1. Maintain accurate patient information input 2. Implement a standardized balance based on service provided 3. Request co-pays based on level of care the patient receives 4. Verify insurance for non-emergency patients before and/or during treatment Consistent Collection Methodology Best Practices
- 16. 2009 Partner with a solution provider experience in working with self-pay liabilities and regulatory compliance. Service Provider Partnerships Best Practices
- 17. 2009 For more information, questions, or to see the white paper, contact: Best Practices Sandra Pinette spinette@finrx.com 800-220-4451 ext. 1023