Regulations in the Emergency Department and Beyond

Navigating Point of Service Collections

Overview

Status of ED Collections

Regulatory Requirements

ED Collection Best Practices

The further along the revenue cycle a patient moves, the more difficult and costly it becomes to collect payment.

Cos

t to

Col

lect

Patient leaves hospital

Time

Cost to Collect

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.

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

Revenue Potential

2009

ED point-of-service collections represent an opportunity to collect 1-3% more in net revenue

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 stabilized3. 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 Patientswith Emergent Conditions are Seen in the ED

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

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

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

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

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

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

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

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

2009Partner with a solution provider experience in working with self-pay liabilities and regulatory compliance.

Service Provider

Partnerships

Best Practices

2009

For more information, questions, or to see the white paper, contact:

Best Practices

Sandra Pinettespinette@finrx.com

800-220-4451 ext. 1023