Carolina AAHAM November 7th, 2017 Geoff Miller, President PRC/HHF SELF PAY COLLECTIONS Carolina AAHAM November 7th, 2017 Geoff Miller, President PRC/HHF

Common Types of Revenue Cycle Outsourcing Medicaid Eligibility Insurance follow up and Denials Management Workers Compensation Third Party Liability Coding Pre Service functions EBO, 1st Party Collections Bad Debt Collections Patient Financing

Pre-Service Functions Communication with Patient about their expected balance before visit is becoming very important Pre-service collections are handled differently across healthcare. Elective or other procedures where self pay balance can be accurately estimated is more easily collectable Conveying estimated charges or collecting before visit if possible Confirm insurance information and other instructions

EBO and Bad Debt 1st party collections Day 1 to 120 3rd party collections Day 120+ Patient friendly calls for collection of money, insurance Scrubs for insurance, bankruptcy, demographic and other information Processing in charity identification and financial assistance Payment plan monitoring

Patient Financing Huge emerging need. Hospitals need cash and patients need flexible terms 29% rise in deductibles since 2015 Different types of patient financing Recourse Non recourse Funded vs not funded Interest free and interest bearing options for patients

Self Pay Collections-Methods Patient Contact typically done via Phone and mail Texting and emails are desired by both patient and agency but due to regulation or lack thereof, it is a risky practice Agency web portals IVR systems

Collection Methods Most of the industry is extremely focused on the patient experience Treatment of patients is paramount Call recordings Speech analytics Skip Tracing methods

Telephone Communication-TCPA Landlines numbers represent 30% Cellphone 70% Must be able to scrub and identify landline vs cell phone Many challenges due to the TCPA to be able to communicate with patients via cell phone, especially without consent TCPA was never intended to effect collection industry but the type of technology we use, agencies and creditors alike have been affected. Obtaining Consent is critical Different approaches to each

Telephone Communication-TCPA One call rule for reassigned numbers 2015 TCPA declaratory ruling by FCC paved way for applications to be developed to block unwanted or suspected spam calls, also blocks legitimate business calls

FDCPA and CFPB FDCPA created in 1977, extremely antiquated Doesn’t address today’s modern technology Has many grey areas where consumer attorney’s benefit greatly, such as what constitutes harassment or technical violation interpretations of letters Dictates when you can call someone 8am to 9pm in their time zone, but cell phones present challenges here Case law interpretations are non consistent due to the unclear areas of FDCPA CFPB rulemaking on collection industry due out soon which may make things more restrictive in some areas but may address modern technology and clear up the grey areas.

Credit Reporting FCRA Fair Credit Reporting Act (FCRA) is a huge source of lawsuits in the collection industry Main issues are: Furnishing and reporting old/inaccurate information Failing to follow debt dispute procedures Requesting a credit report for an impermissible purpose Still a good collection tool, very few things in place to give leverage to collect Considered extraordinary collection event with 501 (r)regulations

Date of Default Also becoming a larger area of concern for collection activity as it relates to EBO collections and credit reporting State laws and federal laws to consider. Date of default maybe important in whether an EBO company can collect in 1st party name Can not credit report earlier than 180 days from date of default

Data exchange, Data Security, Cyber Risks Largest exposure of risk to our Clients and our industry Cost of breach is very high with letters and credit protection Insurance costs for Cyber Liability coverage are still very high Must consider most secure ways to exchange critical data Must consider best ways to store, encrypt and secure data Third party audits are the due diligence that all partners should be required to do, particularly with PHI and credit card data PCI audits very important

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