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

2. 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

3. 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

4. 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

5. 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

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

7. 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

8. 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

9. 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

10. 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.

11. 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

12. 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

13. 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

14. Questions/Comments