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Archive for the ‘Billing and Collections’ Category

Creditor Rules Apply to Healthcare Providers

Last August (2009) the Federal Trade Commission implemented a new law regarding the way businesses prepare for the protection of consumers’ credit information and privacy. These are the “Red Flag Rules.” As many people have unfortunately experienced, identity theft is a real problem in today’s society – to the tune of $54 billion. One study showed this figure is up 37% in less than two years!

Regardless of your medical discipline and type of practice, your patients rely on you to protect their identity. Healthcare providers are settling into maintaining compliance with HIPAA rules for patient privacy. Now they are faced with financial privacy practices.

So what do you need to know to comply with Red Flag Rules?

1. Understand your role as the creditor. If you bill patients for any coinsurance and/or copays you become a “creditor.” This includes any payment plans for any uncollected amounts. Whether you finance it or work with another funding source, you are responsible for the patient’s identity protection.

2. You are NOT a creditor if you require payment at the time of service, or before, services are rendered. Once the patient leaves the premises with an unpaid balance, you become the creditor.

3. You are NOT a creditor if you take all acceptable forms of payment at, or before, services are rendered. This includes credit and debit cards.

4. Once you set up a payment plan, regardless of terms and conditions, you have essentially held yourself out as a creditor. This is called a “covered account.” Therefore, you are responsible for implementing at “TPP” or Theft Prevention Program under the Red Flag Rules.

What can you do now?

1. Develop Policies and Procedures specific to your practice to identify Red Flags that may point you to identity theft.

2. Develop ways to protect patient identity. This includes monitoring your own colleagues as well as patients.

3. Train and educate staff on how to spot someone trying to be admitted under a stolen identity. Forged driver’s licenses, insurance cards, etc may be immediate Red Flags.

4. Always double check the patient’s information in your systems to a current photo ID. Especially addresses where bills are sent.

5. Notify law enforcement if you notice trends where patients call about suspicious bills from your office.

6. Review and revise your policies, training and your internal auditing processes on a regular basis. This is important whether you are a one-clinician practice or a large healthcare system.

Remember, it is your responsibility to identify any and all Red Flags that may jeopardize a patient’s identity.

Visit the Federal Trade Commission’s website at www.ftc.gov for many other resources, or contact a healthcare practice consultant regarding Red Flag Rules. We even provide a low-risk worksheet to get you started.

For more information on this or other ways to improve your clinical processes please contact Jeff Dance, Senior Consultant at KeySys Health, LLC or call: 205-612-1750.


Jeff has more than 20 years experience consulting with organizations to develop sound policies and procedures to comply with internal and external standards. His unique experience has allowed him to see the clinical, administrative and payer aspects of healthcare.

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Improve Cash Flow for Your Practice in Today’s Healthcare Environment

In today’s economic turmoil cash is not only king, but is taking on god-like status. Revenue Cycle Management (RCM) is the current financial discipline needed in all medical practices for sustained success. From hospitals, to physician practices, to the virtual world of medical supply and service ordering, RCM is truly a discipline.

New ways of ensuring patient eligibility and payment responsibility are necessary. Never shy away from developing and instituting policies on your Over The Counter Collections (OTC) Here are some practical tips to help your practice collect cash “over the counter.”

1. Define the process. You don’t need a PMP or Six Sigma expert. Just plain common sense and discipline is needed to understand and apply the steps from referral to getting the patient’s account to a zero balance.

2. Educate and train your staff on the process and the expected goals. Everyone is responsible for ensuring sound financial performance in your medical practice.

3. Keep a scorecard. Nothing works better than posting results. Define the metrics and measure your success. OTC goals should be identified daily, weekly and monthly. Also make sure to celebrate your successes.

4. Audit the process on a regular basis. This includes not only the process but also the compliance with the process. Never forget to make sure you listen to the front line. They should always have input on how to make it better.

5. Automate! There are many billing software solutions healthcare consulting firms that are discipline specific to enable you to use real time eligibility. You’ll know what is expected of the patient and there is immediate accountability.

6. Ask for payment up front. Co-pays, coinsurance, and deductible amounts are all part of the OTC. Take credit and debit cards but make sure you have controls in place to protect this information.

Lastly, remember this point… You are not a bank! Therefore, don’t institute policies that make you one. Instead use these pointers, in addition to your overall intake, billing and collections processes to improve your cash collections. Many practices don’t see the front counter as a place to transact business. What happens at, and over the counter is critical in maintaining your financial success.

Jeff Dance is a Senior Healthcare Consultant at KeySys Health, LLC. He has over 20 years experience in the provider and payer aspects of healthcare. KeySys Health, LLC is a Birmingham, Alabama based healthcare consulting firm that specializes in working with small to medium sized clients to provide sound return on investment in the areas of EHR/EMR, regulatory compliance, revenue cycle management, branding and marketing. Contact us at 205.421.1700 for more ways we can help your practice succeed.

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