Collecting those secondary payments and deductibles?
Yes, it is that time again when we are receiving many deductibles being adjusted from our Explanation of Benefits. And this year, we are feeling the effect more than ever.
To make this process run smoothly, make sure to verify that you have internal processes to get the bills out to your patients or their secondary insurers in a timely manner. Remember, your secondary payers have the same timely filing issues as all other payers, and the last denial you want to see is one for untimely filing.
Do you have a written policy and procedure internally for those patients who cannot afford their secondary payment? This has become a big issue with audit procedures, and providers are being asked for their written policy on hardships by auditors.
What forms do you have in place? Who in your company can make the decision to approve or deny a hardship form that has been completed by a beneficiary? If it is denied, who sets up the payment plan?
Accompanying this article, I am providing you with a sample template of a policy you need to put in place if you do not have one. You will need to complete it with your company information and the selected personnel who will be verifying these forms.
I even suggest you obtain copies of patients' bills and any “proof” you can obtain to validate the financial hardship form. Writing off the 20 percent copay or deductible without appropriate documentation is not allowed and should not be tolerated within your operation.
Your policy should read as follows at a minimum:
Financial Disclosure Policy
________________(Name of company) utilizes a financial disclosure form that meets compliance standards set forth by the industry. It is not the practice of (name of company) to routinely waive 20% co-insurance amounts for any patients that are on service or have received services.
Patients are given the choice to complete a hardship form in the event that the 20% will cost them financial hardship in meeting their monthly expenses. (Name of company) will determine if the patient meets the hardship guidelines by utilizing the national poverty guidelines as a benchmark. (Name of person who will assume responsibility to approve or deny form goes here) will be responsible for reviewing the hardship forms and determining if the patient meets these guidelines.
If the patient is accepted, then the 20% co-pay may be written off. If the patient is declined, a payment plan will be set up per the guidelines, on a monthly basis.
Please see the attached form that is currently being utilized by (name of company). All employees have been educated on this policy and our form. All sales reps and employees are aware that advertising to write off the 20% co-pay for referrals is against the law and will not be tolerated by (name of company).
The national poverty guidelines for 2008 are published in the Federal Register as shown. You may use these as a baseline for determining whether a patient meets the poverty/indigent guidelines. I am not saying you have to go directly by these figures, but you must develop guidelines and show in your policy how you determine financial hardships.
I am also going to provide you with a financial hardship form that has been developed for clients' internal use. Please feel free to utilize this form or develop your own using this as a template.
As you can see, there is a lot to this. Many providers do not have an appropriate policy in place to verify that they are not routinely waiving the 20 percent copay or collecting the deductible.
With the reduction in reimbursement and all of the changes in our industry, this may be your profit you are giving away. Get to work and implement these policies and procedures, and educate your staff accordingly.
| 2008 HHS Poverty Guidelines | |||
|---|---|---|---|
| Persons in Family or Household | 48 Contiguous States and D.C. | Alaska | Hawaii |
| 1 | $ 10,000 | $ 13,000 | $ 11,960 |
| 2 | 14,000 | 17,500 | 16,100 |
| 3 | 17,600 | 22,000 | 20,240 |
| 4 | 21,200 | 26,500 | 24,380 |
| 5 | 24,800 | 31,000 | 28,520 |
| 6 | 28,400 | 35,500 | 32,660 |
| 7 | 32,000 | 40,000 | 36,800 |
| 8 | 35,600 | 44,500 | 40,940 |
| For each additional person, add | 3,600 | 4,500 | 4,140 |
| Source: Federal Register, Vol. 73, No. 15, Jan. 23, 2008 | |||
Jane Bunch is owner of Jane's Healthcare Consulting based in Marietta, Ga. A reimbursement specialist, Bunch delivers educational seminars, helps develop corporate compliance plans and serves as a consultant for fraud and abuse cases. She can be reached at 770/366-0644 or by email at billhme@aol.com.
