Quicker Wins for Early Out Healthcare Receivables · for Early Out Healthcare Receivables ... Collections and FSA/HSA Payment ... regulations for Section 501(r)(4) through 501(r)(6)

Quicker Wins for Early

Out Healthcare Receivables

December 16th, 2014

Patient Payment Collections in the Age of the ACA

2 | Proprietary & Confidential

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


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


Panelists

Pam Kirchner, CEO

- BCA Financial Services

Dave Yohe, Director of Marketing

- BillingTree

Will Stagl, Moderator


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.


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.


Panel Discussion

Client Perspective

Legal Perspective

Patient Perspective

ARM

Perspective


Outlook: Medical Debt Under ACA


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?


Audience Poll

Which services do you offer as an agency to

your clients?

Web portal

IVR

Agent-assisted phone

All of the above


501(r) Compliance and Collections


• 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


• 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)


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.


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.


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.


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?





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?


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


Collections & FSA/HSA Payment Processing





HealthPas Gateway

ARM Underwriting

HealthPas Gateway +

Underwriting


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)


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


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


Questions & Answers


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 –

[email protected]

Thank You

mailto:[email protected]

Documents

Quicker Wins for Early Out Healthcare Receivables · for Early Out Healthcare Receivables ... Collections and FSA/HSA Payment ... regulations for Section 501(r)(4) through 501(r)(6)