Mnet Health News delivers the latest news and information articles for the world of healthcare.

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Consumer Reporting Agencies Announce Changes to Medical Debt Reporting

Three of the major U.S. consumer reporting agencies, Equifax, TransUnion and Experian, recently announced a new National Consumer Assistance Plan, which includes changes to reporting consumers’ medical debts. The plan became effective in the state of New York starting March 8 after cooperative discussions and a settlement agreement between the agencies and New York Attorney General Eric Schneiderman.

It will eventually be implemented nationwide, according to the attorney general’s office.  Equifax, TransUnion and Experian are consumer reporting agencies that maintain consumer credit reports on approximately 200 million consumers. The CRAs compile credit information via voluntary submissions from data furnishers, such as collection agencies.

According to the Consumer Financial Protection Bureau, 43 million people in the U.S. have medical collections on their consumer credit reports. In December 2014, the bureau also announced it would require reports from the major CRAs on accuracy and how disputes from consumers are being handled.  Medical debt is a huge market in the credit and collection industry. In fact, healthcare-related debt accounted for nearly 38 percent of all debt collected in 2013 and 52 percent of all debt collected in 2010, according to surveys by ACA and Ernst and Young.

The new plan for the CRAs aims to enhance their ability to collect complete and accurate consumer information and will provide consumers more transparency and a better experience interacting with credit bureaus about their consumer credit reports.  During discussions in the months leading up to the agreement, the New York attorney general and other state attorneys general allowed the CRAs to collaborate in an unprecedented manner to share industry best practices and develop a plan that will offer consistent and meaningful benefits to consumers.

ACA International, as part of a Medical Debt Collection Task Force led by the Healthcare Financial Management Association, contributed to developing best practices, released just over a year ago, to help make paying medical bills an easier and fairer proposition for consumers. The best practices for healthcare providers and their business partners include following up with CRAs when a consumer’s account is resolved.

The National Consumer Assistance Plan announced by Equifax, TransUnion and Experian also includes following up with CRAs, and focuses on enhancements in two primary areas: consumer interaction with national CRAs and data accuracy and quality.  The settlement agreement between the New York attorney general and the CRAs that likely resulted in the National Consumer Assistance Plan states, “CRAs shall prevent the reporting and display of medical debt identified and furnished by collection furnishers when the date of the first delinquency is less than 180 days prior to the date that the account is reporting to the CRAs.”

This means medical debts won’t be reported until after a 180-day waiting period from the date of delinquency.  Date of delinquency, as defined in the Fair Credit Reporting Act, is “the month and year of the commencement of the delinquency on the account that immediately preceded collection activity, charge to provide or loss, or similar action.”  This date needs to be determined by the provider and furnisher based on the underlying financial agreements and the creditor’s policies for when an account becomes “delinquent.”

Typically, the date of delinquency will precede the date of placement with the agency.  The 180-day waiting period for reporting medical debts in the agreement will allow insurance payments to be applied, according to the New York attorney general. The CRAs will also remove previously reported medical collections that have been or are being paid by insurance from consumers’ credit reports.  

Debt collection agencies whose healthcare provider clients request that they report consumers’ accounts to the three CRAs also rely on them to follow up when the account is paid.  Tom McGregor, president and CEO of DataTrac Receivables Recovery in Anderson, S.C., said deleting consumers’ paid medical accounts from their report altogether might not address the issue of improving their credit rating.

“We all understand that typically a medical incident or a bill incurred as a result of medical necessity is not a voluntary purchase, such as going to Best Buy and buying a TV,” McGregor said.  “Since we’re negatively impacting their credit file when we place [an] item, why shouldn’t it be positively impacted when we mark it paid?”

McGregor spent 12 years of his career working in credit reporting and, at that time, he thought more data was better.  “Then the emphasis switched to accuracy of data—you didn’t want to delete anything unless it was [from] a mistake or error,” he noted.  He said the agreement between the CRAs and attorney general, in terms of deleting consumers’ paid accounts, seems like a quick fix more than a solution.  “The accuracy is critical; there is no doubt about that. If the data is not accurate, it is useless to begin with,” McGregor said. “It looks to me that it could ultimately compound a bad problem rather than resolve it.”

Implementation of the agreement requirements will occur over three years and 90 days from the March 8 effective date and includes three phases.  Requirements for medical debt collections, including the delay of sending accounts to CRAs and removing paid medical bills from consumers’ credit reports, are included in phase three. CRAs have until the completion date to meet those requirements.  CRAs have within six months from the effective date to complete phase one and 18 months from the effective date to complete phase two of the implementation plan.  “The implementation date is going to be important on this,” said Mark Rukavina, a principal at Community Health Advisors in Chestnut Hill, Mass.

As more details on the agreement emerge, it is important for agencies working in healthcare collections and their healthcare provider clients to communicate about their expectations and plans going forward.  Healthcare providers that do allow collection agencies they work with to report patients’ unpaid medical accounts to CRAs should contact them to make sure they are working on systems to comply with the agreement.

“A lot of the details aren’t completely clear at this point,” Rukavina said. “It would be prudent for hospitals to be talking to their agencies about this, and it would be prudent for agencies to let their hospitals know that they are fully aware of the agreement.”

 

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Price Transparency: American Hospital Association Issues Price Transparency Toolkit for Providers

In response to the increasing consumer demand for informative and clear price information about their healthcare, the American Hospital Association has developed a new resource for healthcare providers, Achieving Price Transparency for Consumers: A Toolkit for Hospitals.  According to the AHA’s Community Connections blog, the increase in higher deductible health plans and coinsurance is causing consumers to pay more of their healthcare costs out of pocket.  

“This means that consumer demand for meaningful and transparent price information will only continue to grow,” according to the blog. “To meet this demand, hospitals and health systems must take a critical look at where they currently fall on the price transparency spectrum and take steps to improve how they communicate pricing information with patients and their community.”

The goal of the AHA in developing the toolkit is to prompt conversation and action by allowing hospitals to evaluate their current programs and have access to examples of what other providers do to ensure price transparency, as well as sample price transparency tools.  In addition to examples of other providers’ price transparency plans, the toolkit has a self-assessment checklist, Web-based tools, and studies on price transparency and guides that have been provided to consumers.  More information: http://bit.ly/1mBC70t

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CMS Delays ‘Two Midnights’ Rule

Enforcement of the controversial “two midnight” payment policy for short visits to the hospital has been delayed until the end of April.  

This action should allow Congress the opportunity to pass a package that repeals a sustainable growth-rate formula set in motion by Medicare when the body meets on April 13.  This new piece of legislation encompasses a delay of six months in the enforcement of this payment rule, a point that many hospitals find impairs their clinical decisions and thus unfair.

The CMS has been asked to offer additional advice on payment for short stays at the hospital by the healthcare community when proposed payment rules are released for 2016.  These rules should go in to effect on October 1.  

The policy in question presupposes that an admission into the hospital was valid if the patient’s stay lasted long enough to cover two midnights and that if this was not the case, then outpatient observation would be required.  The reason this policy was created originally was to address a spike that appeared in observation stays; thought to be a reaction to hospital fear that Medicare auditors would question patient admissions.

Originally CMS first announced the two-midnight policy back in 2013.  However, actual enforcement of the rule has been delayed time and again through both regulatory and legislative action.  The most recent delay came to an end in March.

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Changing the Price Transparency Landscape

Price transparency is not a new concept for healthcare providers, but as more consumers have insurance thanks to the Affordable Care Act—as well as high deductible plans with, in some cases, higher out-of-pocket costs—providers are working to improve access to accurate cost information. 

According to a report from The Commonwealth Fund released in November 2014, 21 percent of adults with health insurance spent 5 percent or more of their income on out-of pocket healthcare costs over the past year (excluding premiums), and 13 percent spent 10 percent or more. Low-income adults were the most likely to have high out-of-pocket costs, with 41 percent of those making less than $11,490 a year spending 5 percent or more of their income on out-of-pocket healthcare costs and 31 percent spending 10 percent or more.

As a result of these higher out-of pocket costs, patients have more interest in determining what they will pay in advance, and that trend is also fueling efforts to improve price transparency.  According to the Healthcare Financial

Management Association, which has a task force on price transparency, “The intended outcome of price transparency is to provide patients and other care purchasers with the information they need to make an informed choice of provider.

Price transparency is just one component of the information that care purchasers need to make this choice; the quality and safety of services a provider delivers, for example, are other important components of the information a care purchaser needs.”  From a healthcare provider perspective, improving price transparency may mean evaluating who within a health system is best able to provide cost information for patients, according to Torrey Sundall, the enterprise executive director of patient financial services for Sanford Health, a health system based in South Dakota.

“I would describe it as a healthcare provider’s opportunity to improve the patient experience by providing that education and information upfront to a patient so that they can make an informed decision regarding their care from a cost standpoint,” Sundall said. “A lot of the healthcare providers across the nation [are assessing] their internal capabilities of providing [an] accurate and timely quote or estimate. And you’re seeing a lot of providers who are trying to figure out ways to improve that, whether it’s through internal efforts or engaging in a third-party vendor system.”

Providers and representatives of insurers, consumers and others in the healthcare industry involved with the

HFMA’s Price Transparency Task Force are also focusing more on the extent patient interest in their out-of-pocket costs is fueling the trend in access to information. That focus, along with how overall price transparency can be achieved and challenges with the process, is evaluated in the HFMA’s Patient Friendly Billing® 2006 report, Consumerism in Healthcare: Achieve a Consumer-Oriented Revenue Cycle.

“In that report, we go through what price transparency is from a patient perspective,” said Terry Rappuhn, leader of HFMA’s Patient Friendly Billing® and a former hospital system administrator.  “It has examples and objectives on what hospitals can do to achieve price transparency.”  Rappuhn stressed that efforts to improve price transparency are always evolving and will continue to get better.

“There has been an increase in interest from patients and consumers on prices as a result of the high-deductible health plans,” Rappuhn said. “That’s been happening for a number of years and…it’s going to continue to evolve. You can’t just flip a switch and say, ‘Tomorrow I am going to have price transparency.’  You have to build it. That’s why I think it’s evolving and it will continue to get better.”

According to the HFMA report, providers can achieve price transparency by providing consumers information that is meaningful to them. “Ultimately, the objective is to provide patients with easy and timely access to information that clearly explains their financial obligation to pay for health services—in most cases, in advance of receiving those services,” according to the report.

In regards to providing meaningful information, patients must understand how their individual plan benefits impact a price estimate, Sundall said. For example, if an insured patient is price shopping multiple providers and that patient only has gross charges from the providers, he may make a decision that actually results in more expensive care.

The most accurate information on out-of-pocket expenses is available by taking into consideration the allowed amount from individual insurance plan benefits. It takes a coordinated understanding.  However, as a patient’s likely first point of contact, providers have to work to issue the best price information available as an out-of-pocket cost estimate.

It can be challenging because the cost for one procedure could vary based on the patient’s condition, the services they need, any complications that occur and even the type of supplies a provider may use to complete the procedure. “Those complexities can make it very difficult to come up with a price estimate that doesn’t have a wide range to it,” Sundall said. “I think patients are looking for that estimate that is as accurate as possible. But sometimes just due to the complexity or the potential complexity of the services, you have to provide that patient with a range of those potential costs. 

The challenge there is having appropriate communication with the patient so that they understand that this is just an estimate, not a guarantee of what their charges will be. There may be an unknown variable that is not determined until after the provider has started the procedure. ”

Providers issuing estimates can recommend that patients contact their insurance company next to determine coverage for the service and out-of-pocket costs, and ultimately make the best informed decision on where to receive their medical care.  “What’s important is for a patient to really understand their own insurance benefits. 

[And] there is a level of coordination that’s needed between the provider and the payer to arrive at an accurate quote of what that person’s actual out-of-pocket responsibility is going to be,” Sundall said.

The Affordable Care Act and Price Transparency

Under the Affordable Care Act, hospitals are required to make available a list of their standard charges for items and services, according to an American Hospital Association report from July 2014, Price Transparency Efforts Accelerate: What Hospitals and Other Stakeholders are Doing to Support Consumers.

Under section 501(r) of the Affordable Care Act, which regulates nonprofit hospitals’ ability to maintain their tax-exempt status, hospitals are also required to establish and widely publicize written financial assistance (FAP) and emergency medical care policies. The 501(r) regulations were finalized in December 2014, and the final rules apply to a hospital facility’s taxable years beginning after Dec. 29, 2015.

Sundall stressed that price transparency is more than just providing a list of charges for services, but the requirements in the Affordable Care Act will prompt healthcare providers who have not focused on price transparency to this point to increase and improve their efforts.

“Appropriate scripting and communication will be important now that the 501(r) requirements have become final,” Sundall said. “Typically you want to provide a price estimate to a patient as soon as possible so they have the knowledge ahead of time to make an informed decision. But then you also have to maintain compliance with 501(r) and make sure you’re educating that patient about your financial assistance policy. You likely have to educate that patient about your financial assistance policy before engaging in discussions regarding your expectation of payment.”

The Affordable Care Act has also contributed to employers offering high-deductible health plans to their employees, leading to more inquiries about costs.  According to The Commonwealth Fund report, as healthcare premiums rise, many employers and individuals are selecting insurance plans with higher deductibles and copayments in an attempt to keep premium costs in check. Overall, 13 percent of people with private health insurance whose plans include a deductible now have deductibles equivalent to 5 percent or more of their income; that figure includes 25 percent of adults with low incomes and about 20 percent of adults with moderate incomes($11,490 to $45,960 a year for a single person).

Over the next few years, assessing how health insurance is working for consumers will be a critical measure of the Affordable Care Act’s success, according to The Commonwealth Fund.  But the healthcare law is increasing consumers’ awareness about their medical expenses.  “The Affordable Care Act is impacting the demand for price transparency,” Rappuhn said. Additionally, the 501(r) requirements are doing more to influence providers’ price transparency efforts.

“The 501(r) requirements, I think, [are] causing the hospitals to really step back and be more systematic about both price transparency and what they communicate to patients,” Rappuhn said. “It does require more transparency in what your financial assistance policies are, and that’s a good thing.”

Challenges and the Future of Price Transparency

Overall, Sundall said all health systems want to find a way to improve the patient experience by providing them with accurate cost information in advance.  “When you do that, I think you’re going to have greater patient retention; the patient in general is going to be happier with their care and want to come back to you for future healthcare needs,” he said.

According to the HFMA report, there are many important questions to answer about price transparency:

Will consumerism in healthcare bring about a decline in healthcare consumption, as patients become more discerning about purchasing healthcare services?

Will consumerism facilitate necessary preventative care?

Will providers and payers be able to provide meaningful price and quality information to allow consumers to make decisions about healthcare value?

Will consumers be willing and able to assume the administrative complexities and financial burdens of consumer-directed health plans?

Will providers find ways to compete with convenient care centers offering pricing advantages?

Will the widespread use of health savings accounts generate sustainable savings?

Rappuhn said the most important goal for price transparency is to work on it with consumers’ needs in mind. “I think for this year, the message is to keep working on price transparency as hard and fast as you can because it’s continuing to be more and more important,” Rappuhn said. “Whatever you’re doing, you just have to continue to get better and make it broader.”

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IRS Finalizes Charity Care Rules


In less than a year, nonprofit hospitals will be required to comply with final regulations on access to financial assistance policies, billing and collection procedures and notification periods, as well as creating community health needs assessments, among other things, under section 501(r) of the Patient Protection and Affordable Care Act of 2010 in order to maintain their tax exempt status.

The Internal Revenue Service and U.S. Department of the Treasury issued proposed regulations offering guidance on the statutory requirements of 501(r) in 2012 and 2013, and they sought comments on the proposals before publishing the final rules on Dec. 31, 2014.  

The final rules were effective Dec. 29, 2014, and apply to a hospital facility’s taxable years beginning after Dec. 29, 2015. For taxable years beginning on or before Dec. 29, 2015, the regulations expressly allow a hospital facility to rely on its reasonable, good-faith interpretation of 501(r).  The following is a summary of some of the additional key final rules published in the Federal Register.

Community Health Needs Assessments

Section 501(r) requires a hospital to conduct a community health needs assessment (CHNA) at least once every three years and to adopt an implementation strategy to meet the community health needs identified through the assessment.  CHNAs must be made widely available to the public by:

  • Conspicuously posting the report on a website.
  • Making a paper copy available for public inspection upon request (and without charge).

Financial Assistance Policies

Hospitals are also required to establish and widely publicize written financial assistance policies (FAP) and emergency medical care policies.  To ensure patients have the information they need to seek financial assistance, the FAP must be “widely publicized” within the community it serves, which may be satisfied by making them available on a website and in paper form upon request.

The final regulations require a hospital facility’s FAP to:

  • List the providers, other than the hospital facility itself, such as private physician groups or third-party providers delivering emergency or other medically necessary care within the hospital facility.
  • Specify which providers are and are not covered by the hospital facility’s FAP.

A hospital’s FAP must also specify the eligibility criteria for financial assistance and if it includes free or discounted care, and the basis for determining amounts charged to patients. Individuals eligible for financial assistance cannot be held personally responsible for more than the amounts generally billed (AGB) to patients with insurance, including Medicare, Medicaid or private commercial insurance.

A hospital must include a conspicuous written notice that informs patients about the availability of financial assistance on each billing statement. The notice must include both a telephone number of the office or department that can provide information about the FAP and FAP application process and the direct website address where copies of the FAP, application form and plain language summary may be obtained.

Extraordinary Collection Activities and Notification Periods

Hospitals are required to make reasonable efforts to determine whether an individual is eligible for assistance before engaging in extraordinary collection actions (ECAs), such as selling debt or garnishing the patient’s wages.

Extraordinary collection actions include obtaining payment of a bill for care covered under the FAP through a legal or judicial process; selling an individual’s debt to another party or reporting adverse information about an individual to credit agencies; or deferring, denying or requiring payment before providing medically necessary care based on nonpayment for previously provided FAP-covered care.

There are several notification requirements in place before hospitals, as well as their third-party debt collection partners, can begin ECAs and to contact patients regarding outstanding bills.  Providers must notify patients about

FAPs before discharge and during the 120-day billing period after receipt of the first post-discharge billing statement.

Additionally, patients have up to the 240th day after the first post-discharge billing statement to apply for financial assistance.  If the patient applies within that time, the hospital needs to suspend ECA activity until it makes a determination whether the individual is eligible for financial assistance.

In accordance with the language of the Fair Debt Collection Practices Act, the final regulations amend the initially proposed requirement for written ECA notifications.  A hospital facility is now only required to provide written notification of those ECAs that it (or other authorized party) actually “intends to take” rather than a description of each and every ECA a hospital “may” take in the future. Additionally, the final regulations specify a hospital facility (or third party collecting a hospital facility’s debt) need not provide this notice unless it actually intends to initiate an ECA.

Revocation of Hospital’s Tax-Exempt Status

Failure to meet any of the requirements set forth in the final regulations may have grave consequences, including the revocation of a hospitals’ tax-exempt status and an excise tax for failing to conduct a CHNA or adopt the CHNA’s implementation strategy.

“However, if a hospital fails to meet a requirement, but the failure is neither willful nor egregious, the hospital can correct and publicly disclose the error to have it excused, thus avoiding revocation of tax-exempt status, but the excise tax would still apply,” said U.S. Department of Treasury Deputy Assistant Secretary for Tax Policy Emily McMahon in a blog post on the department’s website.

The rules indicate the IRS will consider all relevant facts and circumstances when determining whether revocation of tax-exempt status is warranted as a result of a failure to meet one or more 501(r) requirements, including whether the organization’s practices and procedures were routinely followed and were reasonably designed to promote and facilitate overall compliance with 501(r), as well as whether the noncompliance once identified was promptly corrected.

Overall, the IRS stressed the final rules follow the same format of what was proposed in 2012 and 2013 while making the process for hospital facilities easier.  “In practice, many of these requirements took effect shortly after the [Affordable Care Act] passed in 2010,” McMahon said. 

“Charitable hospitals have been required to make a good-faith effort to comply with the statutory requirements since the law was passed, and have been able to rely on the Treasury’s proposed regulations pending finalization. These final rules adopt the same framework of proposed regulations but simplify the compliance process for charitable hospitals, while continuing to provide meaningful guidance on protections for patients and requirements to assess community health needs.”

More information: http://1.usa.gov/1zWVCRe and http://1.usa.gov/1ztjxY7

 

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News & Notes

OIG Will Review Two-Midnight Rule

The Office of the Inspector General will review the two-midnight rule in 2015, HealthLeaders Media reports. Under the rule, Medicare beneficiaries who are admitted to the hospital for fewer than two nights should be treated as outpatients. The OIG has found that short inpatient stays cost millions of dollars in excess payments to hospitals. http://bit.ly/1yFMEbA

Survey: Uninsured Lack Understanding of Affordable Care Act Coverage

Some people who stand to benefit from the Affordable Care Act struggle to understand how coverage works, according to the Kaiser Family Foundation. For example, many of the uninsured respondents to the survey could not correctly answer questions that required calculating the amount an insured person would have to pay for a hospital stay (61 percent) or an out-of-network lab test (91 percent) based on the plan’s cost-sharing requirements.  http://bit.ly/1ELRfNr

Spending Per Privately Insured Grew in 2013

Privately insured Americans spent more on medical services in 2013 even though they used fewer of them, according to the Health Care Cost Institute. Healthcare spending averaged $4,915 per enrollee in 2013, up $185 from the year before.  Moderate growth in private insurance spending has occurred since 2010.  http://bit.ly/1oshWCJ

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Mnet Financial Survey Measures Provider Views to Ensure Exceptional Service

Mnet Financial has released a new client survey to medical providers across the country to evaluate the views and practices of medical business offices that make use of their services.  The survey is designed to analyze data such as which products the provider is using, the support and responsiveness of the client services and account management teams, as well as the convenience and ease-of-use of products designed for patients and providers alike.

“Mnet Financial is known throughout the healthcare world for providing exceptional service to our clients” said Mnet Financial CEO David Hamilton.”  “We believe that the best way to maintain such a great reputation is to stay connected with each one of our clients; regularly searching out areas of service that we can improve upon” said Hamilton.  “That’s really the whole point of the surveys that are being sent out to the providers we work with; we want to provide best-in-class service but we need client feedback to ensure consistent improvement” Hamilton said.

So, if you are currently a client of Mnet Financial, it's likely you have received your invitation to take the survey.  But what if you’re not the kind of person who likes to vocalize your opinions about processes and vendors?  The survey can be completely anonymous and is only personalized if the person filling it out chooses to provide their personal information and requests to be contacted by Mnet Financial.

The survey is extremely simple to fill out and easy to access.  Since reports show the majority of people would prefer to complete a survey online, the Mnet Financial survey is sent to clients through an email containing a link taking that person directly to the survey website.  The survey is also very short and to-the-point and is designed to take up a minimal amount of a provider’s time.

“We look at the feedback that comes from the providers we interact with as extremely valuable” said Stacey Vink, Compliance Officer at Mnet Financial.  “Busy professionals are taking time out of their hectic schedules to help shape the customer experience for themselves and other providers throughout the country.  We are extremely grateful for each and every survey that is completed because it helps us raise the bar that much higher” Vink said.

Once Mnet Financial has analyzed and evaluated the results from the survey, a full report of the findings is going to be published for Mnet News readers and the public as well.  After that, Mnet Financial will use the feedback that they have received to enhance the customer experience for both patient and provider.

If you haven't yet received your invitation to complete the survey and would like to do so, please find the survey here:

Click here to take survey

 

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Legislation: Congresswoman Introduces Bill to Help Healthcare Providers Comply with Meaningful Use

Rep. Renee Ellmers (R-N.C.) has introduced legislation to ensure that healthcare providers receive the flexibility they need to comply with the Department of Health and Human Services Meaningful Use Program requirements.

According to Ellmers, HHS published a rule in August requiring that healthcare providers perform a full-year electronic health record reporting period in 2015.

“Healthcare providers have faced enormous obstacles while working to meet numerous federal requirements over the past decade,” Ellmers said.

“Obamacare has caused many serious problems throughout this industry, yet there are other requirements hampering the industry’s ability to function while threatening their ability to provide excellent, focused care.”  Ellmers’ legislation, The Flex-IT Act of 2014, will allow providers to report their Health IT upgrades in 2015 through a 90-day reporting period as opposed to a full year.

“By adjusting the timeline, providers would have the option to choose any three-month quarter for the HER reporting period in 2015 to qualify for meaningful use,” Ellmers said.  To date, only 9 percent of hospitals in the U.S. and 1 percent of eligible healthcare professionals have demonstrated the ability to meet meaningful use Stage 2 requirements using certified electronic health record technology, according to Ellmers.

Additionally, the mandates of the meaningful use program are causing financial hardships for healthcare providers.  “The Meaningful Use Program has many important provisions that seek to usher our healthcare providers into the digital age,” Ellmers said. 

“But instead of working with doctors and hospitals, HHS is imposing rigid mandates that will cause unbearable financial burdens on the men and women who provide care to millions of Americans. Dealing with these inflexible mandates is causing doctors, nurses and their staff to focus more on avoiding financial penalties and less on their patients.”  More information: http://1.usa.gov/1xM9dOW

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Health Care HFMA Issues Guide to Navigate Health Care Marketplace

A group of advocacy organizations and consumer groups has released a new guide to help the health care industry improve its price transparency efforts and patients to access price data, according to the Healthcare Financial Management Association.

The Price Transparency in Health Care recommendations were developed to ease patients’ ability to obtain prices as they are responsible for more and more health care costs in today’s market, according to HFMA. “People everywhere want to be smart health care consumers, but information about health care prices is not easily accessible,” said HFMA President and CEO Joseph J. Fifer.

HFMA developed a task force, which includes members from America’s Health Insurance Plans, the American Hospital Association and the Catalyst for Payment Reform, to issue a series of principles for reaching price transparency.  Insurers and providers can use the information to develop their own method to meet the principles.

Key recommendations include: 

·       Health plans should help members estimate their expected out-of-pocket costs based on their current deductible status, along with copayment and coinsurance information.

·       Health plans often have access to price information for many providers in a given region, which they can use to help members factor price into their decision making process.

·       Hospitals should continue to help uninsured patients identify alternatives for sharing their health care costs, including insurance options they may not be aware of.

·       Hospitals should proactively communicate to all patients and community members—including the uninsured—that they may be eligible for financial assistance provided directly by the hospital.

·       Taking insurance eligibility and financial assistance into account, hospitals should offer uninsured people clear information on how to receive price estimates.

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Health Care Costs: Employer Health Care Costs Projected to Increase at Slower Rates

Projected cost increases for all types of medical plans are anticipated to decline by between 0.1 percent and 0.5 percent in 2014, according to results of a survey of insurers and administrators in the United States by Buck Consultants.  The results show the trend of slow, steady declines in medical plan costs since 2010 is continuing.

In a national survey of 126 insurers and administrators, Buck Consultants measured the projected annual increase in employer-provided health care benefit costs. Insurers and administrators providing medical trends for the survey cover a total of approximately 119 people.

The 28th National Health Care Trend Survey found costs are projected to increase at rates that are lower than its recent prior surveys. For example, costs for preferred-provider organization plans could rise by 8.7 percent this year compared to 9 percent in 2013, according to the survey.

Health care maintenance organization plans could increase by 8.6 percent, compared to 9.1 percent in 2013.  Some survey respondents cited reduced utilization as the primary reason for the decrease in health plan costs.  “This may be a result of the economic slowdown and its impact on consumers’ willingness to seek medical treatment,” said Harvey Sobel, a principal at Buck Consultants and co-author of the survey.

“Even though the decline is good news, most plan sponsors till find 8-9 percent cost increases unsustainable.”  According to a Los Angeles Times article on the results of the survey, some experts attribute the slowdown to the remaining effects of the Great Recession. Others say the health care options through the Affordable Care Act are contributing factors, according to the article.

“It’s too soon to tell the impact of public and private health exchanges on trend,” said Daniel Levin, a principal at Buck Consultants and co-author of the survey. “It may take another few years before we really know if (and by how much) the exchanges will ‘bend’ the cost curve.”

More information: http://bit.ly/1qPMxdS

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Medicare CMS Issues Proposed Hospital Inpatient Payment Regulation

The Centers for Medicare & Medicaid Services has issued a proposed rule that would update fiscal year 2015 Medicare payment policies and rates for inpatient stays at general acute care and long-term care hospitals (LTCHs).

This rule builds on the Obama administration’s efforts through the Affordable Care Act to promote improvements in hospital care that will lead to better patient outcomes while slowing the long-term health care cost growth.

The rule’s most significant changes are payment provisions intended to improve the quality of hospital care that reduce payment for readmissions, and hospital acquired conditions (HACs). The rule also describes how hospitals can comply with the Affordable Care Act’s requirements to disclose charges for their services online or in response to a request, supporting price transparency for patients and the public, according to CMS.

“This proposed rule is geared toward improving hospital performance while creating an environment for improved Medicare beneficiary care and satisfaction,” said CMS Administrator Marilyn Tavenner. Specific proposals include:

·       The maximum reduction in payments under the Hospital Readmissions Reduction program will increase from 2 to 3 percent as required by law. For FY 2015, CMS proposes to assess hospitals’ readmissions penalties using five readmissions measures endorsed by the National Quality Forum.  Already, CMS estimates that hospital readmissions in Medicare declined by a total of 150,000 from January 2012 through December 2013.

·       CMS proposes to implement the Affordable Care Act’s Hospital Acquired Condition (HAC) Reduction Program. Beginning in FY 2015, hospitals scoring in the top quartile for the rate of HACs (such as those with the poorest performance) will have their Medicare inpatient payments reduced by one percent.  CMS will respond to comments on the proposal in a final rule to be issued by Aug. 1, 2014.

More information: http://go.cms.gov/1mfhI0o

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Is Your Facility Securing Patient Consent to Contact For Collection Activities?

Last week a United States District Court judge made a decision on a case that had been brought forward by a consumer who claimed that a debt collection call that was made to her personal cell phone was in violation of the Telephone Consumer Protection Act.  The judge chose to dismiss the case in a ruling that stated that upon the provision of the consumer’s cell phone number, she was consenting to being contacted, even by the auto-dialer method that had been used.

Judge Michael Anello, of the Southern District of California, determined in his ruling in the case of Hudson versus Sharp Healthcare that the provision of a cell number as the only contact number does indeed constitute consent under the TCPA, even if the call being placed is done by auto-dialer.

The plaintiff and her minor child received medical attention in September of 2012 at Sharp Healthcare.  While the child was covered under a health plan, the health plan of the plaintiff herself had lapsed although she claimed no knowledge of the lapse.  During the admission process, Ms. Hudson provided Sharp Healthcare with her cell phone number as her only viable point of contact.  She also signed paperwork that specifically gave her consent to being contacted by Sharp if her account became past due.

After the plaintiff finally did fall behind on payment, Sharp Healthcare made use of an auto-dialer system to contact her at her only point of contact-her cell phone.  Hudson finally filed a TCPA lawsuit in 2013.  However, Sharp made a motion for a summary judgment, which was granted by Judge Anello on June 25 of this year.

The argument put forth by Hudson heavily relied on a controversial decision made last year in a district court in Florida.  That case disregarded a ruling from the FCC and found that providing a cell number does NOT illustrate express consent according to the TCPA.  But in the Hudson versus Sharp Healthcare case, Judge Anello specifically addressed the Florida Ruling by saying it “is viewed as an outlier decision and is not otherwise binding on this Court…In line with other courts in this district, this Court treats the FCC Orders as binding.”

In a ruling in January of 2008, the FCC made the determination that prerecorded and auto dialed calls made to cell phones concerning a debt must be made with “express prior consent” by the individual being called.  The Florida case, the Mais decision, is so far the only noteworthy decision to go against that ruling; and currently is being challenged.

So the question becomes “Does my facility require prior consent from patients to call their personal numbers including cell phone numbers; even though the numbers have been provided by the patient at the point of service?”  This issue has become critical because studies show that one in three household overall have no landline; but in households led by people under the age of 29 the number moves to two out of three household having no landline.

Thus, when patients only have a cell phone number to provide at the point of service and file paperwork does not include a patient consent to contact, this virtually prevents any debt collection activity whatsoever as debt collector vendors rely heavily on auto-dialer campaigns to reach out to patients.  Since collection activities are even more important to the financial health of a provider than ever before, such patient consent forms appear to be a high priority.

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