Blog and Helpful Articles

HR Issues and the Employed Practitioner – Part 2

In Part 1 of this blog series, we explored the issue of untimely processing of a clinician’s work, namely locking progress notes and signing off on lab reports and other documents.  This time, let’s look at attendance and punctuality challenges that certainly vex many an administrator.  Remember that we’re looking at this issue from the standpoint of the employed physician.

In the last installment, we touched on the importance of setting, complying with and enforcing policy.  The first reason is that policies provide the framework for the standards of your practice. They also allow the administrator (or office manager) a norm to which you can hold your provider accountable.  We frequently find, especially in practices that are transitioning from small to medium-size, a lack of established expectations, which makes it difficult to enforce a standard.

Don’t sweat the “policy” boogeyman.  Something simple – one issue per policy – that spells out what you expect is sufficient. In the case of time, we expect our providers to be at work on time, ready to see patients at their scheduled appointments.  Include the notice you expect – barring emergencies, of course – when a provider will be out for the day and the method of notification.  The last thing you want is a clinician to email you if you’re not checking emails first-thing in the morning. One manager we know likes a phone call, not even a text message, at least two hours before the start of a shift. She wants to actually hear the employee’s voice on the line!  Also, make sure your policy mentions any sanctions for repeated last-minute sick calls.

The next thing – and we can’t stress this enough! – is to keep track.  The same holds true for any employee who calls in sick.  One method is to use a calendar sheet for each employee.  Lest you think this is overkill, consider the busy practice with a large staff:  you might know someone’s out today but you may not recognize a pattern of sudden absences across one or more months.  Some type of tracking system will reveal the individual who seems to always call out on Mondays, or after a holiday, or on Fridays. Also make a note of last-minute requests to leave early so you can observe any trends.

If your payroll system allows you to run a report of absences, and differentiates between a day off requested in advance and a sudden sick call, great!  The point is to monitor easily and be quick to discuss any abuses.  When staff calls in sick, administrators flex their team and perhaps deploy floaters to cover under-staffed areas.  When a provider calls out, it’s a domino effect of scrambling to cancel the day’s schedule and trying to find new slots for all the displaced patients, who are understandably unhappy about the change.  If your schedule is fully booked weeks in advance, it could jeopardize patient care and patient satisfaction when rescheduled appointments are delayed.

So, to summarize:  set your policy and make sure it’s communicated throughout the organization; track tardiness and absences for all staff members and look for patterns of abuse; and finally, have “the talk.”  The calendar (or payroll report) comes in handy for guiding a conversation with the practitioner; just show the person his or her pattern of absences and explain that the practice can’t continue to experience this level of absenteeism.  You might learn that the provider is experiencing a family crisis – for example – and a temporary change in work hours might help all parties get back on track.  Remember to document your conversation for the personnel file so you can refer to it at a later date, if needed.

In Part 3 of this series, we’ll explore scheduling disagreements.  Hope to see you then!

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Anthem OIG Audit Reveals Coding Issues

Last month, the Office of Inspector General published the report of a compliance audit conducted on one of Anthem Community Insurance Company, Inc.’s Medicare Advantage (MA) contracts.  The OIG concluded that Anthem was overpaid by $3.4 million. 

MA plans’ payments from the Centers for Medicare and Medicaid Services (CMS) are based largely on the anticipated cost of providing medical care to a group of enrollees.  This is called risk adjusted payment.  A large portion of the payment is calculated by assessing the future costs of certain medical conditions attributed to the member and which map to hierarchical condition categories (HCCs).  As with many CMS payment programs, risk adjustment is prospective so that the conditions identified and reported for the member in one year form the CMS payment to the plan in the following year.  To give you an example of the magnitude of these payments, the report states that for the 2015 and 2016 payment years – the period being audited – CMS paid Anthem $2.3 B to provide coverage to 137,000 enrollees.

The OIG has a responsibility to audit government payment programs and identify areas of waste, fraud and abuse.  It identified seven HCCs at higher risk for miscoding and conducted an audit of a random sample of members for whom the associated conditions were reported.  Let’s look at these problem-prone conditions.

Acute stroke.  Strokes are coded at the time they occur, which means they are coded one time.  Once the acute event is over, the patient may have other complications from the stroke, which are coded when evaluated by a clinician, but the stroke itself is referred to as having occurred in the past.  Past conditions are communicated in the language of “history codes,” which are rarely risk adjusted.  In the case of strokes, ICD-9-CM (in effect at the time of the OIG audit) guidelines required reporting a history of cerebrovascular accident (or stroke).  OIG found that 80% of the time, acute strokes were reported when they were really histories.  In one case, the medical record supported stroke as a differential diagnosis. 

Differential diagnoses are “working diagnoses;” they are not confirmed. Instead, they are possible conditions for which the provider will test and evaluate the patient.  Many times, clinicians have several differential diagnoses, which they narrow down as evidence becomes available to point them toward one confirmed condition.

In seven percent of the cases reviewed, there were no records to support the stroke diagnosis (acute or history).

Acute heart attack. As we know, the term acute, denotes something that happens suddenly and is of relatively short duration.  Similar to strokes, acute heart attacks are coded at the time they occur.  In the world of ICD-9-CM coding, however, an acute myocardial infarction, as it’s called, can be coded for the first eight weeks following the event; this means that for a period of time, the provider can and should report the acute code even if the heart attack isn’t occurring at that moment.  There is no such guideline for strokes.  In 63% of the cases in the OIG audit, the condition was coded as acute well beyond the eight weeks.  At that time, the “old MI” code was risk adjusted and would have provided a smaller payment, but the correct code was not was not submitted for payment. For 20% of the cases, no evidence existed at all for acute or old MI.

In a small number of cases, acute stroke and acute MI were coded together with no support for any reported case.

Embolism.  Embolism HCCs include conditions such as pulmonary embolism (PE) and deep vein thrombosis (DVT); the former is an acute event and the latter can be either acute or more infrequently, chronic. An embolism is a clot and when patients develop this condition, which is evident on imaging studies, they are treated with clot-busting drugs and usually, a six-month course of anticoagulants to prevent recurrence. 

Many providers believe that for the period of time the patient is being anticoagulated, they can report the acute embolism codes.  This is incorrect. There is no eight-week guideline as with acute MI.  Emboli are coded when they occur and for the short time the clot is being dissolved, which experts says is approximately two weeks.  After that, for the duration of the anticoagulation therapy, the correct code is “history of,” which is not risk adjusted.  If the clot returns, there will be imaging evidence and the acute or chronic code can be used once again, depending on the evidence.  The OIG report states that Anthem reported incorrect codes in two-thirds of the cases reviewed.

Vascular claudication. The most common condition in this category is peripheral vascular/arterial disease (PVD), which can be reported from a physical examination or from imaging evidence.  In a little more than 25% of the cases, the OIG audit concluded that the reported condition could not be validated.

Major depressive disorder (MDD). This HCC includes not only MDD, but bipolar disorder and schizophrenia.   Psychiatric conditions are diagnosed based on criteria from the Diagnostic and Statistical Manual of Mental Disorders (DSM).  The OIG reported that in 20% of the cases, the reported condition was not supported.  Check out our YouTube video on MDD and the misunderstandings that lead to its mis-coding.

Mis-keying.  The OIG found that in almost 70% of a different sample of cases, coding errors resulted from mis-keying or transposition.  Some examples cited include reporting 205.00 (leukemia) instead of 250.00 (diabetes), and submitting 482.0 (pneumonia) instead of 428.0 (heart failure). 

As expected, Anthem challenged many aspects of the OIG audit that concluded Anthem had been overpaid by $3,468,954 and the OIG refuted each of the plan’s claims.  However, the issue remains that coding errors do happen and in the aggregate, result in gross overpayments.  Some are the result of misunderstandings by providers, such as reporting strokes long after they occur, and others are due to human error. 

All organizations, including small medical practices, must perform compliance activities to assure their coding is accurate and the documentation in medical records is available to support the conditions reported.  Coding can be reviewed for errors by simply examining a sample of problem-prone codes that are easily transposed and checking claims against progress notes.  When errors are found, the plan or provider is duty-bound to request their removal from the payment system, something Anthem wasn’t too keen on doing as reported last summer. 

Faulty understanding of the required evidence for a medical condition, however, can be perpetuated throughout the organization.  For this reason, audits to validate the support for conditions should be conducted by a third-party who can also educate the practice on areas for remediation.  Better to do this yourself than after a large-scale audit that recoups your funding.  

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HR Issues and the Employed Practitioner – Part 1

Every group practice administrator knows that issues with healthcare practitioners – both physicians and non-physician practitioners – occur, if not abound, and pose a great challenge.  It goes without saying that we need our medical practitioners!  Without them, we can’t provide care to our patients.  However, large practices, and those transitioning into large practices, may experience growing pains in establishing and enforcing certain norms.

In our experience, some common provider issues include:  untimely locking of progress notes, failure to process new work (such as reviewing lab results, signing documents) in a prompt manner, tardiness and attendance issues, appointments that significantly exceed their scheduled length, and scheduling disagreements.  This blog series will tackle these topics and provide suggestions from decades of experience in medical practice management.

First, let’s consider things from a policy perspective.  Closing and electronically signing progress notes within 72 hours is a gold standard.  Not only is the progress note a legal document, but a complete note facilitates subsequent care and allows for the timely submission of medical claims.  Policies and procedures (P&P) are not a magic wand that cause employees to automatically comply, but they establish the practice’s standards, and form the basis for enforcing your guidelines.  P&P must be in writing and all relevant staff members must be oriented to their contents.  The issues covered under your P&P should be monitored regularly.  There’s an old adage in administration, If it isn’t measured, it isn’t managed.  This means that if the issue is important enough to formulate a policy about it, as an administrator, you should be monitoring compliance.

Some practices regularly post or share performance metrics and let peer pressure do some of the heavy lifting.  It’s not unusual to have a few clinicians with large patient loads, who are current on all their requirements; their stats on a global report can add subliminal pressure to your non-compliant providers and stimulate a little friendly competition. 

For those of us who are not so lucky, acting on issues quickly is key.  If, for example, you’re running, or receiving from your billing department, regular reports that show performance metrics like open notes, you can promptly address behaviors that deviate from the norm via one-on-one interventions.  When meeting with a provider, it’s important to establish that the provider knows the rule and knows he or she isn’t meeting it.  The next step is to establish a short deadline to have the backlog of unsigned notes completed and locked.  Some providers have a tendency to buck the system and want to do things on their own timetable; others are usually compliant but may fall behind due to extenuating circumstances.  The administrator’s approach may initially be different with each group, but the bottom line is the same: notes need to be closed quickly so the practice’s revenue is not interrupted.

In an effort to encourage compliance, some administrators have been known to step on the slippery slope of reducing the patient schedule, providing more administrative time to the provider to work through the backlog.  While it’s certainly important to assess whether your practice’s patient load is realistic  – that means, evaluating whether it’s counterproductive to completing all work and still maintaining some semblance of a life – don’t be too quick to pare down the schedule, especially if other clinicians with similar loads get their work done on time.  This may set a precedent that will be hard to discontinue and cause resentment among the medical staff.

In accordance with HR policy, all conversations and interactions must be documented by the administrator in case disciplinary actions escalate.  These are also good notes to have during any bonus or contract renewal discussions. For repeat offenders, a Medical Director’s involvement may be needed with the specter of additional disciplinary action looming in the background.

Dealing with tardy work, such as unsigned labs, prior authorizations, documents, etc., should follow the same path.  Monitor – most EMRs have reports that tell you the status of unsigned materials – and take prompt action.

Join us for Part 2 of this blog series where we look at another common HR issue that may be affecting your group practice: absenteeism and timeliness.

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Similarities Among Florida LTC Companies

We often write about differences among the Florida licensed long-term care (LTC) entities but recently someone asked what they all have in common.  Good question!  Here’s a run-down on that information.

Home health agencies come in two varieties:  those that provide skilled care and those that don’t.  Let’s look at each one.

Skilled home health agencies are those that provide skilled care, defined as services rendered by a licensed healthcare professional, such as nursing, physical, occupational and speech therapies and medical social work.  Skilled agencies in Florida require not only a license but accreditation from one of the three national accrediting organizations:  The Joint Commission (TJC), Accreditation Commission for Health Care (ACHC) or Community Health Accreditation Partner (CHAP).  These orgs’ requirements for agencies go above and beyond the State’s guidelines, and the accreditation process includes a policy review and site visit.

Skilled agencies have a two-step process which takes approximately nine months, and this timeframe depends on many factors.  The first step is to apply for State licensure, which includes a scheduled on-site survey.  Once the license is issued and an initial accreditation is awarded, (the process may take up to six months), the agency then begins providing skilled care to patients. These services may be paid for by insurance or by the client, or may even need to pro bono. When the agency has provided care to a requisite number of patients, the second step is to indicate its readiness for an unannounced accreditation survey, which must be completed within one year.

After the agency passes the second accreditation survey, it receives a lengthier accreditation approval.  The period of time for accreditation is affected by how long it takes the agency to provide care to the required number of skilled patients, the accrediting org’s scheduling availability, and if there are any issues to be remediated after the survey.

Non-skilled home health agencies provide non-skilled care, meaning those that are not rendered by a licensed professional as described above. These services include personal care (assistance with activities of daily living [ADLs] and instrumental activities of daily living [IADLs]), as well as homemaker/companion services.  In Florida, these agencies take approximately five months to proceed through the licensing process; there is only one survey, and it is scheduled. Accreditation is not required, but is available.

Nurse registries are under another Florida LTC license type and resemble skilled agencies with some distinctions.  Nurse registries can provide skilled and non-skilled care, but no therapy services; the only skill is nursing care.  The licensing process is similar to the non-skilled agency in that there is only one survey, which is conducted by the State, and it is announced.  Nurse registries may have limitations in payor acceptance, so it behooves anyone considering this license type to inquire of the major plans in the area to be sure they will pay a nurse registry to care for an enrollee. Accreditation is not required, but is available.

Florida also offers registration for Homemaker Companion Service (HCS) companies.  These are relatively quick to get started and offer only non-hands-on care.  Homemakers and companions can provide light housekeeping services, transport and accompany clients on outings and offer services such as keeping company with the client, playing board games, etc. An HCS can be operational in approximately 30 days.

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OIG Finds Errors in Humana Compliance Audit

When the Centers for Medicare and Medicaid Services (CMS) risk adjustment data validation (RADV) audit identified coding errors for one Humana contract representing members in South Florida, the Office of Inspector General (OIG) conducted its own audit.  We should recall that the OIG’s role is as an independent entity whose mission is to promote integrity, efficiency, and accountability within the Department of Justice so as to combat fraud, waste and abuse. 

The OIG’s audit focused on ICD-9-CM codes (the coding version in effect in 2014) submitted for 200 randomly selected enrollees and which mapped to 1,525 hierarchical condition categories (HCCs).  HCCs are the basis for the majority of the payments made from CMS to MA plans on behalf of enrollees each month.  The bottom line of the OIG review is that payments should have been based on 1,359 HCCs instead, representing an overpayment to Humana of $197 million in 2015. 

Some big take-aways from the lengthy OIG summary report are:

  • Underpayments and overpayments are two sides of the same coin.  Although we might think it’s to the federal government’s advantage to have underpayments, both are errors and both are costly.  Underpayments affect the MA plan and the providers of care because payments do not reflect the true anticipated cost of providing care to a member.
  • OIG concluded that about 82% of the HCCs that factored into Humana’s payments represented medical conditions that were not supported in the medical record. This point is a daily fact for those of us in the business of auditing risk adjusted payments.  One way to mitigate the potential for unsupported conditions is to have providers list the evidence of each MRA diagnosis in a static portion of the progress note.  This is not a magic wand, of course, but the process of documenting actual evidence forces the provider to review it more critically and, in our estimation, confirm that it is accurate.
  • Another important point is the assertion in the OIG report that although a diagnosis may be listed in a progress note or medical record, there must be documentation that indicates the condition was “monitored, evaluated or treated.”  A recent CCG blog advises providers to mentally shift their focus away from believing risk adjusted payment is based on the member’s illnesses and consider it dependent on the PCP’s documented management of those illnesses.  What can coding staff do in this regard?  Scrutinize medical documentation to assure PCPs are actually assessing the condition on each date of service that it’s reported and hold the provider’s documentation to the tried-and-true M-E-A-T standard.
  • For about seven percent of the HCCs, OIG concluded that additional diagnoses should have been – and were not – submitted to CMS, and could have factored into MA plan payments. Some of our clients inquire about the need to report more than one diagnosis code for each HCC, and our response is always the same:  report everything you are M-E-A-T-ing for your patient, regardless of the HCCs.  This means that if a member has several conditions that map to the same HCC, it behooves the clinician to report them all because: 1) the patient actually has the conditions and the progress note is a legal document, 2)  one or more conditions mapped to the same HCC may be disallowed due to faulty support or a M-E-A-T-less record, and another condition will carry the payment.

We would be remiss not to remind you that all coders are not equally skilled at identifying medical condition support or objectively assessing their work for errors.  The ‘independent’ aspect of the OIG adds support to the idea of a third-party coding audit; independent entities are not influenced by the hierarchy of your organization and their only agenda is to validate the codes submitted for payment.

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What We’re Reading – Guidance for Employers Considering Vaccine Mandates

Last year, the Equal Employment Opportunity Commission (EEOC) issued the first guidance for employers regarding the COVID-19 vaccine. Recently, the Occupational Safety and Health Administration (OSHA) released additional guidance, especially for employers grappling with difficult issues: should they require employees to be vaccinated? How should they handle recent CDC guidance on masks?  Three great articles provide information.

In December, law firm McDermott Will & Emery (MWE) covered the vaccine mandate and reminded employers of federal laws that provide for certain legally protected exceptions for disability and sincerely held religious beliefs.  State laws may add additional requirements or protections, which need to be fully explored with your employment attorney.

MWE’s coverage of the OSHA update makes it clear that adverse reactions to vaccines are considered work-related by OSHA for those employers who mandate vaccination.  This means that employers must notify OSHA within 24 hours of an employee’s inpatient admission for a reaction or within eight hours of the employee’s death from same. In addition, employers must report the adverse reaction on the OSHA 300 recordkeeping log if the reaction meets the recording criteria, which include days away from work, restricted work or transfer to another job or medical treatment beyond first aid.

The revised mask guidelines, as reported by HR Executive, are a little thornier; here too, keep in mind that laws vary from state to state.  For employers who have mostly remote workers, the mask changes have minimal impact. But for those in industries that require in-person work, and especially those whose employees are in close proximity – such as manufacturers, retailers and restaurants – the answer is not so clear. Another factor which would impact the employer’s action is whether it has a vaccination requirement. 

Some employers feel comfortable requiring employees to disclose if they’ve been vaxxed, while others don’t want to deal with the hassle of documenting, storing and protecting this information. As reported in one study, about 41% of employers will ask employees to voluntarily disclose if they’ve been vaccinated, while 32% will not and 27% are unsure. 

One thing is abundantly clear:  employers need to become (and remain) well-informed of the nuances of any course of action regarding COVID-19, vaccinations and safety protocols.  As new information becomes available, make sure you have a solid source to guide your workplace decisions. MWE’s attorneys regularly report updates and provide their legal perspectives, and other well-respected employment law firms probably do the same. 

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What We’re Reading – Home Care Turnover Remains Stable at 65.2%

Turnover has long been the bane of many a home health agency administrator, and in 2019, rates had increased.  Cue in the COVID-19 pandemic and fears raged as turnover rates were projected to soar.  Imagine the surprise to find that rates remained flat for 2020, – less than a 1% year-over-year increase! – a marvelous feat considering COVID.  Insights are summarized in the 2021 Home Care Employee Retention Survey Report, which conveys 2020 perspectives from 850 home care providers. 

Legendary workforce challenges last year included widespread anxiety over the virus, child care needs due to school closures, unpredictable shifts from clients canceling visits, lack of PPE – an almost endless list.  Caregiver shortage was the biggest area of concern for home care agencies, dwarfing the next most significant concerns of COVID business impact and caregiver churn by 56% and 58%, respectively.  Although 60% of providers said the pandemic increased caregiver churn, more than 40% improved retention by focusing on training and development, followed by scheduling (26%) and communication (22%).

Last year, nearly 84% of the survey respondents provided some form of caregiver benefits, up from 81% in 2019. The most common forms of benefits were travel reimbursement, paid time off and health care.  The last interesting factoid from the survey is the conclusion that though convenient, internet-based recruitment (including through social media platforms) were not the most effective.  The best retention rates are for those employees recruited from an employee referral program, which in light of staffing issues plaguing our economy in 2021, seems like a word to the wise.

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A Fundamental Disconnect of Risk Adjustment Documentation

When CMS launched the risk adjustment model for Medicare Advantage payments beginning in 2003, the reason for the change – in many minds – was shortened to, essentially, being paid more for sicker members.  While this is one part of the rationale, it can lead to a fundamental disconnect on the justification for the added payments.

Some are under the impression that the key is identifying the member’s chronic conditions that map to the CMS-HCC model.  While this may be true, it’s only part of the story.  The basis for the payment is for the management of the member’s chronic conditions with HCCs.  So, in a nutshell, plans and providers are not paid because the member is “sick” but because they are managing the care of a sick member by assessing and treating those conditions as evidenced by the medical documentation – a seemingly subtle but big difference.

The mental shift then requires that providers not only justify the existence of HCC conditions but when they list those diagnoses in the assessment of a progress note, demonstrate the T-E-A-M of each one.  T-E-A-M is an acronym used by medical coders to reinforce the proper documentation required for a medical condition.  The note must show how the condition is being Treated, Evaluated, Assessed or Addressed and Managed.  This is where many progress notes fall short. 

While the member may, in fact, have a specific medical condition, the diagnosis is “laundry listed” on the note’s assessment with little to no support or T-E-A-M.  CMS has been clear that there must be evidence of an actual assessment and even the American Medical Association defines in the 2021 E/M coding changes, “A problem is addressed or managed when it is evaluated or treated at the encounter by the physician or other qualified health care professional reporting the service.”

Remember: simply refilling medications, ordering tests, adding templated blurbs with counseling information that is not customized to the patient’s reality, and commenting that a specialist is managing the condition do not constitute T-E-A-M and put in jeopardy your risk adjusted payments.

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Trust but Verify: Medical Practice IT

Several years ago, a large provider suffered a computer system crash.  Despite having devoted IT staff and internal policies, it was discovered that the practice’s back-up had not been performed in several months.  We are not “tecchie” so we can’t tell you exactly what contributed to the system failure, but over time, it became clear that this seemingly small issue had large repercussions. The practice lost all data for approximately a three-month period. 

Operational interruption.  When the system went down, the practice was paralyzed.  Imagine something as basic as not having the day’s schedule for all your providers and being ‘surprised’ by every patient who comes in to be seen!  This issue plagued the practice for several months until the patients with follow-up appointments scheduled during the unrecoverable period were seen and new follow- up appointments were scheduled. Fortunately, patients were understanding about the “temporary computer glitch” and seeming chaos reigning in the office.

During the initial days, eligibility could not be checked without asking the patient for a copy of the insurance card and manually checking at the time of the appointment; the practice decided to temporarily forego eligibility checking.  Consequently, co-payments were not collected and billers were tasked with sending statements to collect them.  A system to notify the MA of the patient’s readiness had to be re-created because they usually relied on the EMR for notification, and providers resorted to paper visit notes. But first, a template had to be created.   

Pending referrals during the glitch period could not be completed and the practice had no knowledge of them.  For a few weeks, the referral department was inundated with patient calls regarding referrals and the staff needed to work quickly to resolve the issues and satisfy the patients. These issues were just the tip if the iceberg.

Liability concerns.  Providers, of course, wanted to assure quality patient care and minimize liability in seeing patients without a medical record; basic information, such as medications, chronic conditions and details from the last visit, were verified with the patient.  There was also a blackout on any documents uploaded to the EMR during the glitch, so MAs had to verify if the patient had seen any specialists recently or had any recent hospitalizations, and scramble to obtain the records.   

Billing & revenue issues.  When it was revealed that a few months’ worth of information was unrecoverable, billers could not bill for the preceding few days’ visits because there were no progress notes; the inability to bill resulted in credit balances for those patients who had paid their co-payments. Similarly, they had no ability to refute denied claims or to defend themselves in a payment audit because the progress note was irretrievable. 

Like peeling an onion, we could go on listing the challenges that resulted from this issue, but the point of this message is to spotlight the importance of verification.  As managers, we cannot blindly trust vendors and employees to whom we delegate certain functions without verifying that the work is being done.  In the case of IT, this means assuring that your vendor is performing back-ups according to the schedule you established and that the backed-up information is accessible and complete. 

As we slide into the 2021 hurricane season, this is a good time to meet with your IT staff and review the issue of back-ups.  When and how is information backed up?  What information is backed up?  When was it last tested?  What is the vendor’s plan for disasters and recovery?  Don’t just read a vendor’s report or disaster recovery policy; dialogue with the representative until you’re satisfied that your practice’s information is protected.  And then verify that it is. Not only is this an issue with operational and financial ramifications, but legal and HIPAA concerns as well.

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What We’re Reading – Collecting Past-Due Patient Balances

Whether it’s a virtual or in-person visit, if a patient’s plan has a co-pay, the doctor’s office has to collect it and the patient has to pay it. Since the pandemic and with a lot of Americans struggling with layoffs, business closures, etc., this might be more difficult to do, and many practices are probably running into this issue.  What usually happens is the patient can’t pay at the time of visit and the practice opts to send a bill or defer the payment until the next visit.  When the next visit comes and the patient still can’t pay, your accounts receivable for patient balances starts to go out of control with higher debts than ever. Here are some great tips on how to lower those balances and bring in the revenue you need to keep your practice going.

1. Look for other payment options.

In cases where a whole family goes to the same office, maybe one person has a credit balance and you can transfer it to satisfy another family member’s account or bring down that balance.

2. Re-train front desk staff.

Whether it’s training new staff or retraining, this step is mostly about remembering not to ask a yes or no questions like “Can you pay your balance today?” Chances are good that, if asked in that fashion, most people would answer no. It’s important to remind your patient of an outstanding balance and follow it up with, “How would you like to pay: cash, check, credit?”  Or if your office is set up for it, you can suggest Zelle, Venmo, Cash app, etc.

3. Ask a staff member to step up.

In every office there is at least one person – hopefully more than one! – who always goes above and beyond, has great customer service, doesn’t take no for an answer but is so polite about it, the patient doesn’t even realize it. Consider making that individual the outstanding balance “Remind-er;” you might possibly give that person an incentive to close out outstanding balances.  Example: If your Remind-er can knock down the balance by so much within a certain timeframe, give him/her an extra day off, a small bonus, a sought-after parking space.  Creativity is key!

4. Don’t keep chasing patients.

Every practice has that patient who, no matter what you do, just never pays the balance. Establish a policy on the number of calls, statements, etc. you are going to send out because calls take time and statements cost money.

5. Make the consequences clear, and stick to them.

Once you set your policy from Step 4 above, you need to clearly define penalties or costs if the patient doesn’t pay, and then enforce them.  If you don’t, some patients will take advantage and ruin it for those other patients who follow the rules. So, if you say that after so many attempts, your account will be turned over to a collection agency, you need to follow through with that.

6. Dismiss when necessary.

Most of the time, no doctor wants to terminate a doctor-patient relationship unless it’s absolutely necessary. In cases where a patient constantly has outstanding balances, ignores reminders and costs you time and money to collect, you do have the option to end the relationship/  Make sure to issue the patient a reminder and give a 30-day grace period to allow the patient to find a new provider.  During that time, you will need to see them for “urgent” issues so you’re not charged with patient abandonment. Be sure to research the statutes in your state in case they differ from this information.

No practice will ever not have outstanding patient balances but if everyone follows the steps above on a daily basis, you can keep those balances at a reasonable level. Aren’t you glad you came across an article that’s given you a leg-up on pesky patient accounts?!

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