/ en Sat, 26 Apr 2025 01:15:12 -0500 Tue, 07 Jan 25 14:30:38 -0600 /standardsguidelines/2020-10-15-patient-billing-guidelines <div class="container"><div class="row"><div class="col-md-8"><h2>Patient Billing Guidelines</h2><h3>Approved by AHA Board of Trustees</h3><h3>April 20, 2020</h3><p><em>The mission of each and every hospital is to serve the health care needs of its community 24 hours a day, 7 days a week. Their task is to care and to cure. America’s hospitals and health systems are united in providing care based on the following principles:</em></p><ul><li><em>Treating all people equitably, with dignity, respect and compassion</em></li><li><em>Serving the emergency health care needs of all, regardless of a patient’s ability to pay</em></li><li><em>Assisting patients who cannot pay for part or all of the care they receive</em></li></ul><p><em>The following guidelines outline how all hospitals and health systems can best serve their patients and communities. They underscore hospitals’ commitment to ensuring that conversations about financial obligations do not impede care, while recognizing that determinations around financial assistance require mutual sharing of information by providers and patients. Additionally, they balance needed financial assistance for some patients with the hospital’s broader fiscal responsibilities in order to keep their doors open for all who may need care in a community.</em></p><p><em>These voluntary guidelines represent the AHA’s expectations of what the hospital and health system field can and should do to address issues of coverage, billing and debt collection, and accountability. The guidelines are largely adapted from what is already required in federal law for tax-exempt hospitals (*) and are intended to align with a core principle of universal coverage. Specifically, all individuals should have access to and ensure they are enrolled in a form of comprehensive health coverage as the primary mechanism for paying for care. Moreover, the guidelines are crafted to reflect the hospital field’s immense diversity. Hospitals will need to adapt these guidelines to the needs and expectations of their particular communities. Hospitals in some states may need to modify use of these guidelines to comply with state laws and regulations.</em></p><h2>Guidelines</h2><h3>Helping Patients Pay for Hospital Care</h3><h4>Helping Patients Qualify for Coverage</h4><ul><li>Hospitals should help uninsured patients identify potential sources of public and private coverage.</li><li>Hospitals should assist uninsured patients with submitting an application for coverage, or direct patients to other services and supports that can help them get enrolled.</li></ul><h4>Helping Patients Qualify for Financial Assistance</h4><ul><li>Hospitals should have a written financial assistance policy.<a href="#fn1">*</a></li><li>Hospitals’ financial assistance policy should describe when care may be free or discounted, and delineate eligibility criteria, the basis for determining a patient’s out-of-pocket responsibility and the method for applying for financial assistance.<a href="#fn1">*</a></li><li>Hospitals should communicate this information to patients in a way that is easy to understand, culturally appropriate and in the most prevalent languages used in their communities.<a href="#fn1">*</a></li><li>Hospitals should publicize their financial assistance policies broadly within the community served (e.g., post on the premises and on the website and/or distribute directly to patients) and share them with other organizations that assist people in need.<a href="#fn1">*</a></li></ul><h4>Providing Financial Assistance to Patients</h4><ul><li>Hospitals should create and adhere to a reasonable and compassionate policy that governs the free care for patients with the most limited means as defined by income below 200% of the federal poverty limit (FPL) combined with a level of assets appropriate for the community.</li><li>Hospitals should create and adhere to a reasonable and compassionate policy that governs the payment obligations for other patients of limited means up to a certain percentage of income and assets, or percentage of the FPL, as appropriate for the community, regardless of insurance status.</li><li>Hospitals should provide a reasonable discount when billing patients of limited means.<a href="#fn1">*</a></li><li>Hospitals should apply financial assistance policies consistently and fairly, without regard to race, ethnicity, gender, religion, etc.</li></ul><h3>Ensuring Fair Billing and Debt Collection Practices</h3><h4>Communicating Effectively with Patients</h4><ul><li>Hospitals should use a billing process that is clear, concise, accurate and patient friendly.</li><li>Hospitals should respond promptly to patients’ questions about their bills and requests for financial assistance.</li><li>Hospitals should provide financial counseling to patients to assist them in paying their bill, and make the availability of this counseling widely known.</li><li>Hospitals should have a written debt collection policy.<a href="#fn1">*</a></li><li>Hospitals should ensure that every effort is made to work together with patients to determine whether the individual is eligible for financial assistance before undertaking significant collections actions, and those efforts can include working with other organizations or entities that can help make the determination.<a href="#fn1">*</a></li><li>Hospitals’ written collections policies should include the actions that may be taken in the event of nonpayment and require an advance notice of at least 30 days to patients identifying the specific action(s) it intends to take, when the action will be initiated, and the availability of financial assistance.<a href="#fn1">*</a></li><li>Hospitals should ensure that staff members who work closely with patients are educated about hospital billing, financial assistance, and collection policies and practices.</li></ul><h4>Oversight of Third-party Debt Collection</h4><ul><li>Hospitals should require any contracted third-party debt collection company to be compliant with the Fair Debt Collection Practices Act.</li><li>Hospitals should require any contracted third-party debt collection company to meet key components of its collection policies as well as any legal requirements that would apply if the action were taken directly by the hospital.<a href="#fn1">*</a></li><li>Hospitals should require regular reports on debt collection efforts, including attestation of compliance with hospital policies and obligations.</li></ul><h4>Protecting Patients from Certain Debt Collection Practices</h4><ul><li>Hospitals’ billing and collection policy should forgo garnishment of wages, liens on a primary residence, applying interest to the debt, adverse credit reporting, or filing of a lawsuit unless the hospital has established that the individual is able but unwilling to pay.</li><li>Hospitals’ billing and collection policy should establish the minimum amounts owed that could lead to debt collection or filing of a lawsuit.</li><li>Hospitals should make multiple attempts to reach and negotiate with patients before proceeding to court action.</li></ul><h3>Ensuring Accountability</h3><h4>Approval of Financial Assistance and Debt Collection Policies</h4><ul><li>The hospital governing body should approve and annually review financial assistance and collection policies, as well as routinely review the status of hospital debt collection efforts.<a href="#fn1">*</a></li><li>The hospital leadership should continually review hospital policies and practices related to these guidelines to ensure they are best serving their patients and communities.</li></ul><hr><p id="fn1">*These guidelines are currently required in federal law for tax-exempt hospitals.</p></div><div class="col-md-4"><p><a href="/system/files/media/file/2020/10/Patient-Billing-Guidelines.pdf" target="_blank" title="Click here to download the Patient Billing Guidelines PDF."><img src="/sites/default/files/inline-images/Page-1-Patient-Billing-Guidelines.png" data-entity-uuid="72a53918-793c-43ea-8d9c-d1b20ce93d15" data-entity-type="file" alt="Patient Billing Guidelines page 1" width="1870" height="2420"></a></p><div class="external-link spacer"><a class="btn btn-wide btn-primary" href="/system/files/media/file/2020/10/Patient-Billing-Guidelines.pdf" target="_blank" title="Click here to download the Patient Billing Guidelines PDF.">Download the Patient Billing Guidelines PDF</a></div><div class="external-link spacer"><a class="btn btn-wide btn-primary" href="/patient-billing-guidelines-affirmation" target="_blank" title="Click here to see how your hospital or health system can affirm the patient billing guidelines.">Affirm the AHA Patient Billing Guidelines</a></div><div class="external-link spacer"><a class="btn btn-wide btn-primary" href="/infographics/2022-08-18-hospitals-and-health-systems-affirming-aha-patient-billing-guidelines" target="_blank" title="AHA Members can click here to see how the hospitals and health systems who have already affirm the AHA Patient Billing Guidelines.">See Hospitals and Health Systems That Have Affirmed the Patient Billing Guidelines</a></div></div></div></div> Thu, 15 Oct 2020 08:05:12 -0500 Billing & Collections /news/headline/2025-01-07-cfpb-finalizes-rule-banning-inclusion-medical-debt-credit-reports <div><p lang="EN-US" lang="EN-US" paraid="1959663768" paraeid="{f5f6db5d-7dd7-49ca-8279-b67cbf71fbc9}{16}">The Consumer Financial Protection Bureau today <a href="https://www.consumerfinance.gov/about-us/newsroom/cfpb-finalizes-rule-to-remove-medical-bills-from-credit-reports/" target="_blank">released a final rule</a> Jan. 7 banning medical bills on credit reports and prohibiting lenders from using medical information in lending decisions. The rule will remove an estimated $49 billion in medical bills from credit reports for nearly 15 million Americans. The CFPB said Americans with medical debt on their credit reports could see their credit scores increase by an average of 20 points.  </p></div><div><p lang="EN-US" lang="EN-US" paraid="738692707" paraeid="{addc9a36-60d3-495c-bb41-1420c477f18c}{235}">The final rule will become effective 60 days after publication in the Federal Register.</p></div> Tue, 07 Jan 2025 14:30:38 -0600 Billing & Collections /aha-center-health-innovation-market-scan/2024-10-15-4-health-systems-team-tackle-drug-development-care-coordination-and-billing <div class="container"><div class="row"><div class="col-md-8"><img src="/sites/default/files/inline-images/4-Health-Systems-Team-Up-to-Tackle-Drug-Development-Care-Coordination-and-Billing.png" data-entity-uuid="cc708067-d6ca-4b77-9008-533ef3e88f67" data-entity-type="file" alt="4 Health Systems Team Up to Tackle Drug Development, Care Coordination and Billing. A silver hand and a gold hand fist bump." width="100%" height="100%" class="align-center"><p>Addressing weighty issues that confront health care, such as increasing access to complex drugs, care coordination within huge programs like Medicare Advantage and streamlining billing processes, is tough for any organization trying to go it alone. So maybe it’s not surprising that four prominent nonprofit health systems — Baylor, Scott & White Health, Memorial Hermann Health System, Novant Health and Providence — have banded together to form a for-profit entity to tackle these challenges.</p><p>The new organization, <a href="https://www.providence.org/news/uf/689043632?streamid=4347370%5C" target="_blank" title="Providence: Leading Health Systems Form New Organization to Transform the Development and Delivery of Health Care Solutions">Longitude Health</a>, will draw on the expertise of founding member organizations while it tries to recruit more health systems and investors over the next 12 months.</p><p>Initially, Longitude Health plans to form three operating startup companies that will focus on pharmaceutical development, improving care coordination and streamlining billing practices. The organization hopes to create additional operating companies in the coming years. Paul Mango, former chief of staff at the Centers for Medicare & Medicaid Services, will be CEO of the new venture, with CEOs from the four health systems comprising the Longitude board.</p><p>“Health systems must transcend traditional care delivery strategies and embrace innovative business models that serve the broader health care community,” said Rod Hochman, M.D., president and CEO of Providence. “To do so, it is imperative that we work with other like-minded partners facing similar challenges to build up new capabilities. By implementing solutions that benefit multiple health systems, we can drive down costs and ensure the sustainability of health care delivery. We will lead the charge in shaping a brighter future for health care delivery.”</p><p>Health system-led ventures like the generic drug company CivicaRx and the data analytics firm Truveta are models that Longitude can build on, Hochman told <a href="https://www.modernhealthcare.com/providers/longitude-health-providence-baylor-scott-white-novant-memorial-hermann" target="_blank" title="Modern Healthcare: 4 nonprofit health systems launch Longitude Health">Modern Healthcare in a recent interview</a>. If Longitude can develop solutions that demonstrate value, the organization will share those with the field, he said.</p><p><span><strong>Initial aims of the Longitude startup companies include:</strong></span></p><ul><li><strong>Improving access to drugs</strong> like monoclonal antibodies used to treat cancer and infectious diseases.</li><li>Working closely with physicians to <strong>limit readmissions</strong>, at the request of Medicare Advantage plans. The company will help health systems refine treatment and improve care transitions.</li><li>Consolidating medical bills into a <strong>single invoice</strong> that shows what a patient owes.</li></ul><p>In January, Longitude plans to hold a competition among the four health system members to determine what Longitude’s next focus should be, which could be related to health information technology, cybersecurity, labor productivity or value-based care.</p></div><div class="col-md-4"><p><a href="/center" title="Visit the AHA Center for Health Innovation landing page."><img src="/sites/default/files/inline-images/logo-aha-innovation-center-color-sm.jpg" data-entity-uuid="7ade6b12-de98-4d0b-965f-a7c99d9463c5" alt="AHA Center for Health Innovation logo" width="721" height="130" data-entity- type="file" class="align-center"></a></p><p><a href="/center/form/innovation-subscription"><img src="/sites/default/files/2019-04/Market_Scan_Call_Out_360x300.png" data-entity-uuid data-entity-type alt width="360" height="300"></a></p></div></div></div>.field_featured_image { position: absolute; overflow: hidden; clip: rect(0 0 0 0); height: 1px; width: 1px; margin: -1px; padding: 0; border: 0; } .featured-image{ position: absolute; overflow: hidden; clip: rect(0 0 0 0); height: 1px; width: 1px; margin: -1px; padding: 0; border: 0; } Tue, 15 Oct 2024 06:00:00 -0500 Billing & Collections <div class="container"><div class="row"><div class="col-md-8"><p>The Centers for Medicare & Medicaid Services (CMS) Sept. 24 issued a <a href="https://public-inspection.federalregister.gov/2024-22054.pdf">final rule</a> that would carve out significant, anomalous and highly suspect (SAHS) billing from Medicare Shared Savings Program (MSSP) financial calculations for calendar year (CY) 2023. This final rule is part of a larger strategy to address SAHS billing activity within accountable care organizations (ACOs) reconciliation. Specifically, the agency also addressed this issue for CY 2024 and beyond in the CY 2025 physician fee schedule proposed rule, on which the AHA <a href="/lettercomment/2024-09-09-aha-comments-cms-physician-fee-schedule-cy-2025-proposed-rule" target="_blank">commented</a>. This rule’s changes are effective Oct. 15.</p><div class="panel module-typeC"><div class="panel-heading"><h2>Key Highlights</h2><p>The rule:</p><ul><li>Finalizes two urinary catheter codes involved in SAHS billing activity for CY 2023.</li><li>Adjusts ACOs’ performance year and benchmark year calculations for CY 2023 to account for this activity, including when CY 2023 is the performance year and when it is used to establish benchmarks for 2024, 2025 and 2026.</li><li>Excludes CY 2023 amounts from factors used in the application cycle for ACOs applying to enter a new agreement period beginning on Jan. 1, 2025.</li></ul></div></div><h2>AHA Take</h2><p>The AHA applauds CMS for recognizing the significant impact that anomalous catheter spending would have on ACO participants and for taking action to carve out these expenditures from ACO financial calculations. Indeed, the recent catheter billing issue increased some ACOs’ total spending by as much as 2%. As such, in many cases, the inclusion of this spending would have led to a loss of shared savings. We are pleased that the agency listened to the <a href="/lettercomment/2024-04-30-letter-cms-administrator-brooks-lasure-higher-spending-two-catheter-codes-and-impact-acos" target="_blank" title="Recommendations from AHA and Others">recommendations</a> from AHA and others to hold ACOs harmless for such spending beyond their control.</p><p>While this is a significant step to mitigate the impact of anomalous spending for CY 2023, the 2023 catheter spending is not the first, and unfortunately likely not the last, instance of suspected fraudulent billing. We are encouraged that this is part of a broader strategy to mitigate anomalous spending and will continue to work with the agency to develop future policies to address this issue. </p><p>Highlights of the SAHS final rule follow.</p><h2>Identifying Codes Displaying SAHS Billing Activity in CY 2023</h2><p>The agency finalized that a health care common procedure coding system (HCPCS) or current procedural terminology (CPT) code exhibits SAHS billing activity when there is a significant increase in claims, either in volume or dollars, with national or regional impact, that represents a deviation from historical utilization trends that is unexpected and is not clearly attributable to reasonably explained changes in policy or the supply or demand for covered items or services. CMS determined that two HCPCS codes displayed SAHS billing activity in CY 2023: </p><ul><li>A4352 (Intermittent Urinary Catheter; Coude (curved) tip, with or without coating (Teflon, silicone, silicone elastomeric, or hydrophilic, etc.) each)</li><li>A4353 (Intermittent Urinary Catheter with insertion supplies)</li></ul><p>Both HCPCS codes were billed at significantly higher rates in CY 2023 compared to 2022 (an increase of 163% for A4352 and over 5,000% for A4353), but CMS could not determine a clear justification for these increases. The agency also analyzed HCPCS code A4351 but determined that it did not constitute SAHS billing activity, as it increased only 16% from CY 2022 to CY 2023. Additionally, the agency reviewed skin substitute codes and determined billing activity increases were explained by deviations in local coverage determinations across Medicare Administrative Contractors.</p><h2>Removing Payment Amounts from Financial Calculations</h2><p>CMS will exclude all Medicare Parts A and B payment amounts for selected catheter HCPCS codes from expenditure and revenue calculations for CY 2023. This includes when CY 2023 is the performance year and CY 2023 is a benchmark year for ACOs in agreement periods beginning on Jan. 1, 2024, Jan. 1, 2025, and Jan. 1, 2026. Amounts also will be excluded from calculating factors used in the application cycle for ACOs applying to enter a new agreement period beginning on Jan. 1, 2025.</p><p>After receiving comments, the agency considered whether amounts also should be removed for CY 2022 and CY 2024. For performance years prior to CY 2023, the agency determined that financial reconciliation already has been completed, and therefore, the policies applied in the SAHS billing rule would not address retrospective billing increases. For CY 2024 and beyond, the agency proposed changes in the CY 2025 physician fee schedule that should be finalized around Nov. 1.</p><p>CMS also received comments requesting the application of guardrails for organizations that may, for example, have shared savings decremented by removing SAHS catheter billing. The agency determined that it would not apply guardrails for adjustments to financial calculations.</p><p>Finally, the agency considered comments regarding making similar adjustments for catheter codes in other programs like the ACO Realizing Equity, Access, and Community Health (ACO REACH), Bundled Payments for Care Improvement  Advanced, and Comprehensive Care for Joint Replacement models. However, it determined that this would be beyond the scope of this rule. CMS states that the Center for Medicare and Medicaid Innovation assessed the effects of SAHS billing on each model and made determinations of whether actions were necessary on a model-by-model basis.</p><h2>Further Questions</h2><p>If you have further questions regarding the SAHS billing final rule, please contact Jennifer Holloman, AHA’s senior associate director of policy, at <a href="mailto:jholloman@aha.org">jholloman@aha.org</a>.</p></div><div class="col-md-4"><a href="/system/files/media/file/2024/09/cms-issues-aco-significant-anomalous-and-highly-suspect-billing-final-rule-bulletin-9-25-2024-f.pdf"><img src="/sites/default/files/inline-images/cover-cms-issues-aco-significant-anomalous-and-highly-suspect-billing-final-rule-bulletin-9-25-2024-f-2.pdf_.png" data-entity-uuid data-entity-type="file" width="640" height="834"></a></div></div></div> Wed, 25 Sep 2024 15:33:26 -0500 Billing & Collections /news/headline/2024-07-29-aha-comments-cms-proposed-rule-mitigate-impact-fraudulent-catheter-billing <p>The AHA July 29 applauded a proposed rule by the Centers for Medicare & Medicaid Services to address concerns raised by the AHA and other organizations about the potential impact of significant, anomalous and highly suspect catheter billing within the Medicare Shared Savings Program. CMS data showed a 20-fold increase in catheter billing from 10 durable medical equipment suppliers over two years, equivalent to a nearly $3 billion increase in spending. The AHA supported CMS' proposal to hold ACOs harmless for SAHS catheter billing that occurred in calendar year 2023, and specifically supported exclusion of catheter billing codes submitted by any supplier from MSSP expenditure and revenue calculations for CY 2023. "Inclusion of this anomalous billing in accountable care organization (ACO) spending figures for CY 2023 would have a severely inappropriate impact on these calculations," AHA <a href="/2024-07-29-comment-letter-cms-proposed-rule-mitigate-impact-significant-anomalous-and-highly-suspect-billing-activity-within">wrote</a> to CMS. "Indeed, the recent catheter billing issue increased some ACOs’ total spending by as much as 2%. As such, in many cases, inclusion of this spending would actually lead to a loss of shared savings." </p> Mon, 29 Jul 2024 14:02:23 -0500 Billing & Collections /2024-07-29-comment-letter-cms-proposed-rule-mitigate-impact-significant-anomalous-and-highly-suspect-billing-activity-within <div class="container"><div class="row"><div class="col-md-8"><p>July 29, 2024</p><p>The Honorable Chiquita Brooks-LaSure<br>Administrator<br>Centers for Medicare & Medicaid Services<br>Hubert H. Humphrey Building<br>200 Independence Avenue, S.W., Room 445-G<br>Washington, DC 20201</p><p><em><strong>RE: Mitigating the Impact of Significant, Anomalous, and Highly Suspect Billing Activity on Medicare Shared Savings Program Financial Calculations in CY 2023</strong></em></p><p>Dear Administrator Brooks-LaSure:</p><p>On behalf of our nearly 5,000 member hospitals, health systems and other health care organizations, our clinician partners — including more than 270,000 affiliated physicians, 2 million nurses and other caregivers, and the 43,000 health care leaders who belong to our professional membership groups, the ���������� Association (AHA) appreciates the opportunity to comment on the Centers for Medicare & Medicaid Services’ (CMS) proposed rule to mitigate the impact of significant, anomalous and highly suspect (SAHS) billing activity within the Medicare Shared Savings Program (MSSP) in calendar year (CY) 2023.</p><p><strong>We applaud CMS for taking quick action to develop proposals to address </strong><a href="/system/files/media/file/2024/04/Coalition-letter-on-Catheter-Spending-Impact-on-ACOs.pdf"><strong>concerns</strong></a><strong> raised by the AHA and other stakeholders regarding the potential impact of SAHS catheter billing.</strong> Specifically, data from the CMS Virtual Research Data Center showed a 20-fold increase in catheter billing on the part of 10 durable medical equipment (DME) suppliers over the course of two years, which was equivalent to an almost $3 billion increase in spending. Inclusion of this anomalous billing in accountable care organization (ACO) spending figures for CY 2023 would have a severely inappropriate impact on these calculations. Indeed, the recent catheter billing issue increased some ACOs’ total spending by as much as 2%. As such, in many cases, inclusion of this spending would actually lead to a loss of shared savings.</p><p><strong>We support CMS’ proposal to hold ACOs harmless for the SAHS catheter billing that occurred in CY 2023. Specifically, we support the exclusion from expenditure and revenue calculations of payment amounts for catheter billing codes submitted by any supplier.</strong> This would include when CY 2023 is the performance year, as well as when it is used for establishing benchmarks for 2024, 2025 and 2026. Additionally, we support that SAHS billing amounts would be excluded from factors used in the application for ACOs applying to enter a new agreement period beginning on Jan. 1, 2025. That said, while this proposed rule would apply only to the MSSP, we encourage the agency also to evaluate impact and pursue similar policies for other ACO programs outside of MSSP. For example, the ACO Realizing Equity, Access, and Community Health (REACH) model appears to have been similarly impacted by anomalous catheter billing.</p><p>We also encourage CMS to evaluate whether additional codes should be carved out of financial calculations for 2023. Some ACOs have reported, for example, that there have been similar increases in billing for skin substitutes (a $2.6 billion increase between 2022 and 2023) that also may artificially skew financial calculations and impact shared savings without action.</p><p>We recognize that even with a 30-day comment period, the process of carving out this spending from financial calculations may result in delays in timelines. Specifically, CMS stated that it anticipates a delay in reconciliation timelines by up to six weeks. <strong>Given the projected delays in reconciliation timelines, we encourage CMS to delay other ACO timelines, such as risk track selection deadlines and participation lists, to ensure alignment.</strong> Indeed, previous performance is an important factor that participants consider when determining whether, for example, they can assume more risk under a different performance track.</p><p>While this proposed rule marks a significant step to mitigate the impact of anomalous catheter spending for CY 2023, this is not the first, and unfortunately likely not the last, instance of ACOs reporting suspected fraudulent billing. <strong>As such, we commend CMS for including proposals to address the impact of SAHS in 2024 and future years as part of the CY 2025 physician fee schedule (PFS) proposed rule.</strong> We have <a href="/system/files/media/file/2024/04/Coalition-letter-on-Catheter-Spending-Impact-on-ACOs.pdf">urged</a> for long-term policies to support the identification of SAHS. For example, we have recommended the establishment of an outlier policy to detect variation in anomalous spending above a certain threshold and remove services from future calculations. There also are opportunities to improve how ACOs report fraud, as well as to better educate ACOs on the process CMS and the Health and Human Services (HHS) Office of Inspector General (OIG) undertake to investigate fraud. As the HHS OIG has previously noted, ACOs are excellent sources to uncover potential fraud, waste and abuse by identifying patterns of unusual billing. We will provide additional comments in response to the CY 2025 PFS proposed rule.</p><p>We appreciate CMS’ timely proposal on this issue and look forward to working collaboratively on developing a longer-term strategy to detect and address anomalous billing. Please contact me if you have questions or feel free to have a member of your team contact Jennifer Holloman, AHA’s senior associate director of policy, at <a href="mailto:jholloman@aha.org?subject=" comment letter proposed rule to mitigate the impact of anomalous and highly suspect billing activity within medicare shared savings program in cy>jholloman@aha.org</a>.</p><p>Sincerely,</p><p>/s/</p><p>Ashley Thompson<br>Senior Vice President<br>Public Policy Analysis and Development</p></div><div class="col-md-4"><p><a href="/system/files/media/file/2024/07/Comment-Letter-on-CMS-Proposed-Rule-to-Mitigate-the-Impact-of-Significant-Anomalous-and-Highly-Suspect-Billing-Activity.pdf" target="_blank" title="Click here to download the Comment Letter on CMS’ Proposed Rule to Mitigate the Impact of Significant, Anomalous and Highly Suspect Billing Activity within the Medicare Shared Savings Program in CY 2023 PDF."><img src="/sites/default/files/inline-images/Page-1-Comment-Letter-on-CMS-Proposed-Rule-to-Mitigate-the-Impact-of-Significant-Anomalous-and-Highly-Suspect-Billing-Activity.png" data-entity-uuid="e6d08773-8155-4678-a0af-41705f88dd0d" data-entity-type="file" alt="Comment Letter on CMS’ Proposed Rule to Mitigate the Impact of Significant, Anomalous and Highly Suspect Billing Activity within the Medicare Shared Savings Program in CY 2023 page 1." width="692" height="900"></a></p></div></div></div> Mon, 29 Jul 2024 09:42:18 -0500 Billing & Collections /fact-sheets/2024-07-18-fact-sheet-hospital-outpatient-department-billing-requirements <div class="container row"><div class="row"><div class="col-md-8"><h2><span><em>The Issue</em></span></h2><p>The National Provider Identifier (NPI) is a unique identification number for covered health care providers (including physicians and hospitals) to help send information electronically more quickly and effectively. Congress is considering legislation that would change current billing practices for Medicare and the commercial insurance market to require each off-campus hospital outpatient department (HOPD) to be assigned a unique NPI as a condition of payment. However, these changes are unnecessary since hospitals already bill according to federal regulations, which require them to bill all payers — Medicare, Medicaid and private payers — using codes that indicate the location of where a service is provided.</p><h2><span><em>Background</em></span></h2><p>Under current law, when a patient is seen at an off-campus HOPD, the HOPD bills for the items and services rendered using the HIPAA-mandated institutional billing claim. The institutional claim requires that the hospital identify the type of bill (TOB) in each claim. Specifically, TOB 13X identifies that the bill is for a “hospital outpatient department.” Additionally, consistent with HIPAA and Medicare’s existing regulations, off-campus services must include the correct modifiers on the bill. Modifier “PO” must be appended to all items and services paid under the outpatient prospective payment system and rendered in an off-campus HOPD. Modifier “PN” must be appended to all items and services paid under the Medicare physician fee schedule and rendered in an off-campus outpatient department. Modifier “ER” must be appended for services in an off-campus emergency department. Moreover, the HIPAA-mandated institutional claim requires that the claim include the name and service location of the provider submitting the claim.<br>Current Medicare regulations require that beneficiaries who are treated at an off-campus HOPD receive notification of their expected financial obligations if they will be receiving bills from both the individual provider and the hospital.</p><h2><span><em>AHA Position</em></span></h2><p>The AHA is opposed to legislative efforts requiring each off-campus HOPD to be assigned a separate unique health identifier from its provider as a condition of payment under Medicare or group health plans. Hospitals are already transparent about the location of care delivery on their bills and this requirement would be duplicative and impose unnecessary and onerous administrative burdens and costs to needlessly overhaul current billing practices and systems.</p></div><div class="col-md-4"><img src="/sites/default/files/inline-images/cover-fact-sheet-hospital-outpatient-department-billing-requirements-850.png" data-entity-uuid="be271b2e-4af4-44d9-b78c-c0f921748c67" data-entity-type="file" width="NaN" height="NaN"></div><p> </p><div class="text-align-center"><p><a class="btn btn-wide btn-primary" href="/system/files/media/file/2024/07/fact-sheet-hospital-outpatient-department-billing-requirements.pdf" target="_blank" title="Click here to download the Fact Sheet: Hospital Outpatient Department Billing Requirements">Download the PDF</a></p><p> </p></div></div></div> Thu, 18 Jul 2024 15:23:27 -0500 Billing & Collections /news/headline/2024-07-11-senate-help-committee-holds-hearing-medical-debt <p>The Senate Committee on Health, Education, Labor and Pensions held a <a href="https://www.help.senate.gov/hearings/what-can-congress-do-to-end-the-medical-debt-crisis-in-america" target="_blank">hearing</a> July 11 on medical debt. The AHA submitted a <a href="/testimony/2024-07-10-aha-senate-statement-what-can-congress-do-end-medical-debt-crisis-america" target="_blank">statement</a> for the hearing that highlighted how the quality of insurance coverage is a driver of medical debt, saying that coverage for many patients is either insufficient or unavailable. The AHA discussed hospital and health system efforts offering financial and other assistance, and that hospitals absorb billions of dollars in losses for patients who cannot pay their bills, mainly due to inadequate commercial insurance coverage. To address the issue, the AHA urged Congress to restrict the sale of high-deductible health plans to individuals with the ability to afford the associated cost-sharing; prohibit the sale of health-sharing ministry products and short-term limited-duration plans that go longer than 90 days; and lower the maximum out-of-pocket cost-sharing limits, among other changes.</p> Thu, 11 Jul 2024 14:45:38 -0500 Billing & Collections /testimony/2024-07-10-aha-senate-statement-what-can-congress-do-end-medical-debt-crisis-america <p class="text-align-center"><strong>Statement</strong><br><strong>of the</strong><br><strong>���������� Association</strong><br><strong>for the</strong><br><strong>Committee on Health, Education, Labor & Pensions</strong><br><strong>of the</strong><br><strong>United States Senate</strong><br><strong>“What Can Congress Do to End the Medical Debt Crisis in America?”</strong><br><br><strong>July 11, 2024</strong><br> </p><p>On behalf of our nearly 5,000 member hospitals, health systems and other health care organizations, our clinician partners — including more than 270,000 affiliated physicians, 2 million nurses and other caregivers — and the 43,000 health care leaders who belong to our professional membership groups, the ���������� Association (AHA) writes to share the hospital field’s comments on medical debt. While we appreciate Congress’s interest in addressing medical debt, we encourage policymakers to do more to prevent patients from incurring this type of debt, rather than focusing on credit reporting and alleviating acquired debt.</p><h2>OVERVIEW OF MEDICAL DEBT</h2><p>More Americans than ever are dealing with medical debt, a consequence of patients not paying some or all their health care bills, despite benefiting from the highest levels of insurance coverage in history. Unlike other types of debt, medical debt can be unexpected, due to an accident or illness. These debts can impact patients’ abilities to pay for necessities, including food, clothing and household items, and can result in patients using savings or loans to address their medical debt. Recent polling by the KFF found that “41% of adults have health care debt according to a broader definition, which includes health care debt on credit cards or owed to family members.”<sup>1 </sup>The survey also showed that:</p><ul><li>U.S. residents owe at least $220 billion in medical debt.</li><li>Approximately 14 million people (6% of adults) in the U.S. owe over $1,000 in medical debt.</li><li>About three million people (1% of adults) owe medical debt of more than $10,000.</li></ul><p>Hospitals and health systems are very concerned about patients’ medical debt. While health insurance is intended to be the primary mechanism to protect patients from unexpected and unaffordable health care costs, for too many that coverage is either unavailable or insufficient. Trends in health insurance coverage that are driving an increase in medical debt include inadequate enrollment in comprehensive health care coverage, growth in high-deductible and skinny health plans that intentionally push more costs onto patients and misleading health plan practices that confuse patients’ understanding of their coverage. These gaps in coverage leave individuals financially vulnerable when seeking medical care. The primary causes of medical debt include the following.</p><ul><li><strong>There are still too many uninsured Americans</strong>. Affordable, comprehensive health care coverage is the most important protection against medical debt. While the U.S. health care system has achieved higher coverage rates over the past decade, gaps remain.</li><li><strong>High deductibles subject many Americans to cost-sharing they cannot afford</strong>. High-deductible plans are designed to increase patients’ financial exposure through high cost-sharing in exchange for lower monthly premiums. Yet many individuals enrolled in high-deductible plans find they cannot manage their portion of health plan expenses. A Federal Reserve report found that 37% of adults could not afford a $400 emergency, an amount $1,000 less than the average general annual deductible for single, employer-sponsored coverage<sup>.2</sup></li><li><strong>Certain health plans provide inadequate benefits that frequently lead to surprise gaps in coverage</strong>. Short-term, limited-duration health plans and health-sharing ministries cover fewer benefits and include few to no consumer protections, such as required coverage of pre-existing conditions and limits on out-of-pocket costs. Patients with these types of plans often find themselves responsible for their entire medical bill without help from their health plan, including critical services such as emergency medical and oncology care. These denials can lead to an accumulation of significant medical debt.<sup>3</sup></li><li><strong>Complex health plan benefit design and misleading marketing can expose patients to unexpected costs</strong>. Many health plans have complex benefit designs that are not transparent to patients, such as what is covered pre-deductible, the interaction between point-of-service copays, coinsurance and deductibles, and poor communication and education about what the plan covers. For example, a recent National Association of Insurance Commissioners report found significant gaps and inconsistencies in how insurers share information about pre-deductible, no-cost-sharing preventive services with their members, resulting in a “meaningful barrier to effective understanding and use of preventive service benefits.”<sup>4</sup></li></ul><h2>HOSPITALS AND HEALTH SYSTEMS ADDRESSING DEBT</h2><p>Hospitals are the only part of the health care sector that provide services to patients regardless of their ability to pay. They underscore that commitment by offering financial and other assistance, including helping patients qualify for federal and state health care programs, such as Medicaid. In doing so, patients can receive regular preventive care, not just episodic care for serious injuries or illnesses. In addition, hospitals absorb billions of dollars of losses for patients who cannot pay their bills, mainly due to inadequate commercial insurance coverage; in 2020, the latest figure available, hospitals provided more than $42 billion in uncompensated care.<sup>5</sup></p><p>This is why hospitals are staunch supporters of ensuring everyone is enrolled in some form of comprehensive coverage. However, we appreciate that closing the remaining coverage gaps may be a longer-term solution and that more immediate steps can be taken. To that end, the AHA has routinely developed patient billing guidelines to help prevent patients from incurring medical debt. The AHA’s Board of Trustees adopted the most recent <a href="/standardsguidelines/2020-10-15-patient-billing-guidelines" target="_blank">set of guidelines</a> in 2020, which reaffirm the hospital field’s commitment to:</p><ul><li>Treating all people equitably, with dignity, respect and compassion.</li><li>Serving the emergency health care needs of all, regardless of a patient’s ability to pay.</li><li>Assisting patients who cannot pay for part or all the care they receive.</li></ul><p>Tax-exempt hospitals are also subject to a federal statute that requires written financial assistance and debt collection policies. These hospitals must wait at least 120 days after sending the initial bill to initiate extraordinary collections actions, notify the patient at least 30 days before taking the collections action and allow patients to submit financial aid applications for up to 240 days following the initial bill.</p><p>Several of the AHA’s guidelines directly address medical debt, including encouraging hospitals to forego adverse credit reporting of outstanding patient bills. So far, nearly 2,800 hospitals and health systems have affirmed their commitment to the guidelines, and the AHA revisits them regularly for updates.</p><p>Some hospitals are taking additional steps to help all eligible patients afford their medical bills, including using programs originally intended for the uninsured. These “presumptive eligibility” endeavors include proactively screening patients for financial assistance eligibility, regardless of insurance coverage or whether a patient has completed a financial aid application. The goal is to limit the need for hospitals to seek repayment by reducing patients’ financial liability to a more affordable amount.</p><h2>FEDERAL OVERSIGHT OF MEDICAL DEBT</h2><p>Policymakers at the federal level have acted to address the burden of medical debt through statutory changes, such as collection practices of tax-exempt hospitals, as well as those made through the Fair Debt Collection Practices Act, as overseen by the Consumer Financial Protection Bureau (CFPB), which impact how medical debt is displayed on credit reports. Recently, CFPB issued medical debt payment products and medical debt collection practices requests for information and a proposed rule to ban credit reporting agencies from incorporating medical debt when calculating credit scores.</p><p>While hospitals and health systems are assisting patients with their bills, policymakers must do more to prevent them from incurring these debts. Rather than focusing on debt relief grants or putting additional administrative burdens on providers, Congress must ensure patients can access comprehensive, affordable health insurance products.</p><p>Some of these suggested changes include:</p><ul><li> Restricting the sale of high-deductible health plans to only those individuals with the demonstrated means to afford the associated cost-sharing.</li><li>Prohibiting the sale of health-sharing ministry products and short-term limited-duration plans that go longer than 90 days.</li><li>Lowering the maximum out-of-pocket cost-sharing limits.</li><li>Eliminating the use of deductibles and co-insurance, and instead relying solely on flat co-payments which are easier for patients to anticipate and for providers to administer.</li><li>Removing providers from the collection of cost-sharing by requiring health plans to collect directly from their enrollees the cost-sharing payments they impose. This approach would eliminate most patient bills from providers altogether.</li></ul><p>Congress could also do more to improve health literacy by funding health navigators, community health workers and financial advisors to assist patients in selecting appropriate health insurance products.</p><h2>CONCLUSION</h2><p>Thank you for your consideration of the AHA’s comments on issues related to medical debt. We look forward to continuing to work with you to address these important topics on behalf of our patients and communities.</p><p>__________</p><p><small class="sm"><sup>1</sup> </small><a class="ck-anchor" id="https://www.healthsystemtracker.org/brief/the-burden-of-medical-debt-in-the-united-states/" href="https://www.healthsystemtracker.org/brief/the-burden-of-medical-debt-in-the-united-states/"><small class="sm">https://www.healthsystemtracker.org/brief/the-burden-of-medical-debt-in-the-united-states/</small></a><small class="sm"> </small><br><small class="sm"><sup>2</sup> </small><a class="ck-anchor" id="https://www.federalreserve.gov/publications/2023-economic-well-being-of-us-households-in-2022-expenses.htm" href="https://www.federalreserve.gov/publications/2023-economic-well-being-of-us-households-in-2022-expenses.htm"><small class="sm">https://www.federalreserve.gov/publications/2023-economic-well-being-of-us-households-in-2022-expenses.htm</small></a><br><small class="sm"><sup>3 </sup></small><a class="ck-anchor" id="https://kffhealthnews.org/news/sham-sharing-ministries-test-faith-of-patients-and-insurance-regulators/" href="https://kffhealthnews.org/news/sham-sharing-ministries-test-faith-of-patients-and-insurance-regulators/"><small class="sm">https://kffhealthnews.org/news/sham-sharing-ministries-test-faith-of-patients-and-insurance-regulators/</small></a><small class="sm"> </small><br><small class="sm"><sup>4</sup> </small><a class="ck-anchor" id="https://healthyfuturega.org/ghf_resource/preventive-services-coverage-and-cost-sharing-protections-are-inconsistently-and-inequitably-implemented/" href="https://healthyfuturega.org/ghf_resource/preventive-services-coverage-and-cost-sharing-protections-are-inconsistently-and-inequitably-implemented/"><small class="sm">https://healthyfuturega.org/ghf_resource/preventive-services-coverage-and-cost-sharing-protections-are-inconsistently-and-inequitably-implemented/</small></a><small class="sm"> </small><br><small class="sm"><sup>5</sup> </small><a class="ck-anchor" id="/system/files/media/file/2020/01/2020-Uncompensated-Care-Fact-Sheet.pdf" href="/system/files/media/file/2020/01/2020-Uncompensated-Care-Fact-Sheet.pdf"><small class="sm">/system/files/media/file/2020/01/2020-Uncompensated-Care-Fact-Sheet.pdf</small></a><small class="sm"> </small><br> </p> Wed, 10 Jul 2024 12:11:44 -0500 Billing & Collections /concord/case-studies/cedar-novant <div></div><div> /* Banner_Title_Overlay_Bar */ .Banner_Title_Overlay_Bar { position: relative; display: block; overflow: hidden; max-width: 1170px; margin: 0px auto 25px auto; } .Banner_Title_Overlay_Bar h1 { position: absolute; bottom: 40px; color: #003087; background-color: rgba(255, 255, 255, .8); width: 100%; padding: 20px 40px; font-size: 3em; box-shadow: 0 3px 8px -5px rgba(0, 0, 0, .6); } @media (max-width:991px) { .Banner_Title_Overlay_Bar h1 { bottom: 0px; margin: 0px; font-size: 2.5em; } } @media (max-width:767px) { .Banner_Title_Overlay_Bar h1 { font-size: 2em; text-align: center; text-indent: 0px; padding: 10px 20px; } } @media (max-width:530px) { .Banner_Title_Overlay_Bar h1 { position: relative; background-color: #63666A22; } } /* Banner_Title_Overlay_Bar // */ .Banner_Title_Overlay_Bar h1 { color: #fff; background-color: rgba(255, 255, 255, .0); box-shadow: none; } @media (max-width:530px){ .Banner_Title_Overlay_Bar h1 { background-color:#000; } } <header class="Banner_Title_Overlay_Bar"><img src="/sites/default/files/2023-06/Concord_Investing_banner1_1170x250.jpg" alt="Banner Image" width="1168" height="250"><div><h1>Novant Health improves patient satisfaction and payment experience in 12 months</h1></div></header></div><div class="raw-html-embed"> /* CntMenuSub */ .CntMenuSub{ margin:20px 0px; padding-bottom: 5px; color: #afb1b1; letter-spacing: 1.5px; font-weight: 400; font-size: 11.2px; } .CntMenuSub a{ text-decoration:none } .CntMenuSub .CntMenuBar{ border-bottom: 1px solid lightblue; } /* if includes a logo */ @media (min-width:361px){ .CntMenuSub.CntMenuSubLogo .CntMenuBar{ margin-top: 10px; float: left; width: calc(100% - 425px); } } @media (max-width:767px) and (min-width:361px){ .CntMenuSub.CntMenuSubLogo .CntMenuBar{ float: left; width: calc(100% - 0px); } .CntMenuSub.CntMenuSubLogo img{ width: auto; } } /* // */ .CntMenuSub .CntMenuBar a:after{ content: "|"; padding: 0 3px 0 6px; color: #555; } .CntMenuSub .CntMenuBar a:last-child:after{ content: ""; } .CntMenuSub .CntMenuSubHome, .CntMenuSub .CntMenuSubParent{ text-transform: uppercase; color: #555; opacity: .9; } .CntMenuSub .CntMenuSubParent{ } .CntMenuSub .CntMenuSubChild{ } .CntMenuSub .CntMenuSubCurrent{ opacity: .7; } .CntMenuSub .CntMenuSubHome:hover, .CntMenuSub .CntMenuSubParent:hover{ text-transform: uppercase; 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document.getElementById("CntMenuSubChild").innerHTML = y[0].innerHTML; </div><div class="row sp_Resource1"> .sp_Resource1 { /*padding: 25px 0 0px 0;*/ } .sp_Resource1 h2 { margin-top: 0px; } .sp_Resource1 h3 { margin: 10px 0 0 0; color: #555; font-size: .7em; text-transform: uppercase; font-weight: 400; letter-spacing: 3px; } .sp_Resource1 h4 { color: #002855; line-height: 1.2em; font-size: 30px; margin: 10px 0 15px 0 } .sp_Resource1 p, .sp_Resource1 ul li { font-size: 16px; } .sp_Resource1_holder { background-color: ; padding: 0; overflow: auto } .sp_Resource1 .sp_Resource1_holder img { margin: auto; display: block; box-shadow: 10px 10px 14px -6px rgba(0,0,0,0.75); -webkit-box-shadow: 10px 10px 14px -6px rgba(0,0,0,0.75); -moz-box-shadow: 10px 10px 14px -6px rgba(0,0,0,0.75); } @media (max-width:767px) { .sp_Resource1 .sp_Resource1_holder img { width: 100%; max-width: 150px; } } .sp_Resource1 .btn { margin-top: 20px; } .sp_Resource1_holder h2 span { color: #d50032; display: block; position: relative; font-size: .8em; } <div class="col-md-10 col-md-offset-1 sp_Resource1_holder"><div class="text-align-center col-sm-4 col-md-3"><a href="/system/files/media/file/2024/07/Cedar_Novant_Casestudy_2023_AHA.pdf" target="_blank" title="Novant Health improves patient satisfaction, dramatically streamlines payment experience in 12 months with Cedar Pay"><img src="/sites/default/files/2024-07/cedar-novant-casestudy-247x320.jpg" alt="Cover image" width="247" height="320"></a> </div><div class="col-sm-8 col-md-9"> Scan </h3> --><h2><span>Case Study</span> <a href="/system/files/media/file/2024/07/Cedar_Novant_Casestudy_2023_AHA.pdf" target="_blank" title="Novant Health improves patient satisfaction, dramatically streamlines payment experience in 12 months with Cedar Pay">Novant Health improves patient satisfaction, dramatically streamlines payment experience in 12 months with Cedar Pay</a></h2><p>Novant Health wanted to make bill payment easy to navigate for patients and help them understand how payments work and insurance benefits apply. After implementing Cedar Pay, Novant Health saw a significant rise in patient satisfaction with the billing process with scores now at 90%. In one year, Novant Health added $30M in patient revenue, while time to payment resolution has dropped by 43%. Digital self-service now accounts for 87% of all patient payments.</p><p><a class="btn btn-wide btn-primary" href="/system/files/media/file/2024/07/Cedar_Novant_Casestudy_2023_AHA.pdf" target="_blank" title="Novant Health improves patient satisfaction, dramatically streamlines payment experience in 12 months with Cedar Pay"><span>Read Case Study</span></a><span> </span></p></div></div></div> /* y-hr3 */ .y-hr3{ clear: both; } .y-hr3 div:nth-child(2) { border-top: solid 2px lightgrey; margin: 50px 0px; height: 0px } /* y-hr3 // */ <div class="row y-hr3"><div class="col-md-3"> </div><div class="col-md-6"> </div><div class="col-md-3"> </div></div><div class="row spacer"><div class="col-sm-8 col-md-offset-2"><div><a href="https://www.cedar.com/novant-health/?utm_source=aha&utm_medium=web&utm_campaign=aha-concord-portcos&utm_term=2024&utm_content=casestudy" target="_blank" title="Cedar "><img src="/sites/default/files/2024-07/cedar-logo-834x313.jpg" alt="Cedar logo" width="417" height="157"></a><h3><a href="https://www.cedar.com/novant-health/?utm_source=aha&utm_medium=web&utm_campaign=aha-concord-portcos&utm_term=2024&utm_content=casestudy" target="_blank" title="Cedar">Cedar</a></h3><p>Cedar is committed to improving the healthcare financial experience for all. With an innovative platform that connects providers and payers, Cedar empowers healthcare consumers with an optimized journey—all powered by data science and interactive design. For Cedar clients, this leads to increased payments, more efficient operations and greater consumer loyalty. To learn more about why leading U.S. healthcare organizations trust Cedar to manage the end-to-end consumer experience from pre-registration to post-visit billing, visit <a href="https://www.cedar.com/?utm_source=aha&utm_medium=web&utm_campaign=aha-concord-portcos&utm_term=2024&utm_content=casestudy">cedar.com</a> and join us on <a href="https://www.linkedin.com/company/cedar-inc./">LinkedIn</a>, <a href="https://twitter.com/CedarNY">Twitter</a>, <a href="https://www.facebook.com/CedarNY">Facebook</a> and <a href="https://www.youtube.com/channel/UCrIA5mF8AiiN5E2_qNFfNOw">YouTube</a>.</p><p>To learn more about Cedar <a href="mailto:kvazquez@cedar.com?subject=I%20would%20like%20to%20learn%20more%20about%20your%20solution&body=I%20would%20like%20to%20learn%20more%20about%20the%20work%20your%20company%20is%20doing%20with%20hospitals%20and%20health%20care%20providers." title="contact Katrina Vazquez">contact Katrina Vazquez</a>.</p></div></div></div> /* y-hr3 */ .y-hr3{ clear: both; } .y-hr3 div:nth-child(2) { border-top: solid 2px lightgrey; margin: 50px 0px; height: 0px } /* y-hr3 // */ <div class="row y-hr3"><div class="col-md-3"> </div><div class="col-md-6"> </div><div class="col-md-3"> </div></div> Wed, 03 Jul 2024 14:41:36 -0500 Billing & Collections