In accordance with its tradition of passing laws which are poorly conceived, inadequately tested, and not capable of implementation, the federal government strikes again. On the heels of the ICD-10 postponement, the administration is now proposing that the Stage 2 meaningful use requirement of electronic medical records be postponed as well. This is welcome news, as physician and hospital groups have petitioned vigorously for this postponement.
Please recognize that this is a preliminary notice. The rule change has been proposed but has not yet been approved. Approval will almost certainly be forthcoming, but at this point, we should not be surprised by any move the government makes, no matter how illogical.
Unfortunately, a potential endgame is gaining clarity.
Step 1: Pass into law a health plan that cannot function successfully.
Step 2: Admit that the plan is a failure despite their best efforts.
Step 3: Announce that we must have a government-controlled single payor system to rescue American healthcare.
PDA has been working to provide an alternative to this endgame. We have worked carefully and deliberately, and the Flagship Physician Network is now up and running. The Flagship is actively helping employers develop self-funded benefits plans, which will primarily utilize PDA physicians and funnel patients in our direction. In addition to the actual network of physicians, the Flagship is now being strongly promoted by a network of benefits agents who understand our structure and support it whole-heartedly. The Flagship potential is becoming a reality. Local interest is growing rapidly, and the Flagship is beginning to attract attention on the national level. PDA physicians who have agreed to participate in the Flagship Network will soon begin seeing a trickle and then a steady stream of Flagship patients. Your patience is appreciated and will be rewarded.
PDA physicians have one and only one managed care contract that interfaces with ObamaCare. Blue Cross Blue Shield has rolled its PPO Advantage plan (an Exchange-based product) into its Blue Choice PPO. Therefore, any PDA physician electing to participate in the Blue Choice PPO will be obligated to care for Exchange patients as well. In this contract, the filing procedures will be the same, and the levels of compensation will be the same.
An estimated 20% of Exchange patients have not paid the premium for their insurance. The Obama administration has granted these patients a 90-day grace period to make their premium payment. Care rendered during the first 30 days to patients who are taking advantage of the grace period falls under the responsibility of the insurance companies. However, the physician must ultimately collect any costs incurred during the last 60 days of the grace period from the patient if the patient fails to make the premium payment. BCBS plans to compensate physicians for care during the last 60 days, but if the premium remains unpaid, BCBS will “claw back” payments leaving the physician office to fend for itself.
When confirming coverage of Exchange patients, the physician’s office will be told how many days of grace period have expired if the payment is more than 30 days delinquent. Although participants in Blue Choice PPO are required to provide care to exchange patients, there is flexibility in appointment scheduling. Please keep in mind that regardless of where the prospective patient is in the grace period, you are still contractually bound to collect only the allowable co-pay for the visit. PDA officially recommends following the guidelines published by the AMA:
(You can create a free log-in for this information without being an AMA member.)
• A step-by-step guide to the ACA grace period,
• Grace period collections policy checklist,
• Model financial agreement language for patients receiving Advance Premium Tax Credits, and
• Sample letter: Grace period notice to patients
The collections policy checklist encourages providers to verify insurance eligibility prior to a patient’s visit and to document the information. It also provides physicians with tips on communicating billing policies to patients and establishing payment plans. If you provide care during the last 60 days of the grace period, you should have the patient sign an agreement with language similar to the following:
I (the patient) also understand and acknowledge that I am personally responsible to pay (the name of the practice) in full for services that my health insurer will not cover due to non-payment of my health insurance premiums.
It is a Brave New World!