ED Collections Aren’t Worth an EMTALA Violation
May 1, 2017 4 minutes read
When it comes to ED collections, timing is everything. “Performing the full registration and the point-of-service collection process needs to be coordinated with multiple factors,” says Miguel Vigo IV, revenue cycle system director at Edward-Elmhurst Health in Naperville, IL.
Patient access must take all these things into account before registering someone:
- the patient’s medical condition;
- whether the patient truly is cleared for registration to be completed;
- the patient’s and family’s need for privacy.
Even with all these challenges, patient access still has a job to do: Get the information they need and enter it into the system as quickly as possible.
“It is a bit of a dance, and the process must leave room for flexibility,” Vigo explains. But he argues that the ED needs to put hard-stop parameters in place to ensure that staff members gather all the appropriate information. If a patient is admitted or placed in observation status, for instance, patient access must enter this information before bed assignment.
Here are two practices Vigo sees as problematic:
- If patient access begins the full registration process prior to the triage and stabilization of the patient and their condition.
“Often times, both clinical and nonclinical teams need to communicate more clearly,” Vigo says.
Clinicians must indicate when the patient is stabilized and the triage process is complete so registrars know they can complete registration. Registrars must check with clinicians if they’re unsure.
At Edward-Elmhurst, ED tracking boards display different colors to show a patient’s status. A green light signals to registrars that the patient is ready for registration to be completed.
“If there is any hesitation, concern, or uncertainty of the patient’s status, the patient access and registration team simply checks with the nurse and/or physician prior to entering the room to begin their work,” Vigo says.
- If patient access begins the full registration process while a patient is receiving treatment.
The patient may not be in an emergent condition at that point. For instance, he or she might simply have a wound that needs suturing. Though not an EMTALA violation, Vigo says, “it is still bad practice to have a full registration completed at that time.”
Understand the ‘Why’
Vigo has found it helpful to educate clinicians on the importance of copay collection in the ED.
“Everyone involved needs to understand the ‘why’ for the point-of-service collection process,” he says.
Often, clinicians assume the sole purpose of upfront collections is to ask patients for money. They even see registrars as interfering with patient care.
“However, there is a huge patient experience piece that plays an important role in point-of-service collections and the subsequent bill that patients receive,” Vigo notes.
When collecting copays, patient access also educates patients on how their insurance works — something that can be very helpful after patients leave the ED.
“There are normally follow-up care appointments, services, and testing needed after the patient’s ED visit,” Vigo explains.
With some insurance know-how, patients leave with a better understanding of what to expect going forward. They also are aware of a contact person.
“For billing questions, we provide the patient accounts’ contact number,” Vigo explains.
“For insurance questions, we provide a direct line to our insurance verification team.”
Good communication and lots of training have produced head-turning results: The ED’s collections increased 20% over the last fiscal year.
“We were averaging around $75,000 per month. We are now collecting over $110,000 consistently,” Vigo says.
SOURCE
- Miguel Vigo IV, Revenue Cycle System Director, Patient Access & Pre-Service Center, Edward–Elmhurst Health, Naperville, IL. Phone: (331) 221-3413. Email: [email protected].
Two Upfront Payment Exceptions
Upfront collections are a major focus for many patient-access departments, but many question whether the process conflicts with federal 501(r) requirements for financial screening. The new charity regulations include some guidance.
“In general, it’s still OK to ask patients to make a payment upfront at the time of service — with two big exceptions,” says Jessica Curtis, JD, senior advisor of the Hospital Accountability Project at Boston-based Community Catalyst. She sees these practices as problematic:
- Asking for upfront payments in the ED. “There is a lot of concern about creating situations where patients who need care and can’t pay upfront either leave the hospital without getting help, or rely on a credit card or loan they can’t repay,” Curtis says. These patients should be encouraged to find out if they qualify for financial assistance. “The new federal guidance strongly encourages hospital staff to wait until patients have either been screened and stabilized or admitted for inpatient care to bring up payment,” Curtis adds.
- Asking patients with overdue balances to pay the past-due amount before they’re seen for nonemergency care. “In this scenario, it’s still OK to ask the patient to pay their portion of cost-sharing for that day’s visit before being seen, like a copay or deductible,” Curtis explains. However, requiring patients to pay the overdue amount before they are seen is considered an “extraordinary collection action” under the new rules.
Curtis says if the hospital cancels or reschedules the patient’s visit until they pay the overdue amount, patient-access staff must give patients these items:
- oral notice about financial assistance;
- a deadline for completing their application;
- hard copies of the policy, a summary, and an application.
“Hospitals have to expedite applications from patients in these circumstances,” Curtis adds.
SOURCE
- Jessica L. Curtis, JD, Director, Hospital Accountability Project, Community Catalyst, Boston. Phone: (617) 275-2859. Email: [email protected].
Registrars must execute duties with pitch-perfect timing.
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