Back to Basics: Reviewing Your Office's Financial Policy
CA CORNER
Kristi Hudson
Office policies and procedures are essential for a practice’s success. It is more than just setting it and forgetting it. Your policies and procedures are living documents that should be reviewed and updated as the practice grows and changes. The office financial policy is one of the greatest tools for success, but it can also be an area of risk and must comply with all the layers of regulation we face today.
Your office’s financial policy should always be compliant with the requirements of your provider agreements and government regulations, consistently applied to every patient, and considerate of the economic challenges people may have. For example, many provider agreements make it clear that you should not collect in advance for services covered by the plan, which means prepays can get you in trouble. If you are unsure if they are allowed in your state or by health plans, check with your state board or legal counsel and refrain from assuming that prepays are legal just because everyone offers them.
A sound financial policy in your clinic can help you avoid the following:
Dual-Fee Schedules: When providers charge more to patients with insurance than patients who pay with cash, which invites problems in most cases.
Improper Time-of-Service Discounts: Discounts must be “reasonable and defensible.” Most experts say between 5 and 15% is reasonable, but make sure you are not discounting deductibles or copayments. That may violate your provider agreements.
Inducement Violations: Be cautious when offering discounts to your patients if you don’t know all the rules. Far too often, we forget that a healthcare “system” regulates us, and we must comply with all layers of the system. Respect the rules and regulations from your board of examiners, provider agreements, state department of insurance, attorney general’s office, CMS, and the Office of Inspector General (OIG). It sounds daunting, but it is possible with the right financial policy.
More importantly, despite having the best, most legal, most enforceable financial policy known to man, always stop and ask yourself, “Is it simple enough that anyone on our team can explain it clearly and concisely?” If your financial policy is so complicated that only one person on the team can explain it, it doesn’t matter that it is compliant. When writing and updating your policies and procedures, your goal is to write them in a manner that the average sixth grader would understand.
Once you have reviewed and updated your financial policy, schedule a training with your team. Policy training communicates expectations and teaches your team how to apply the policy in real-life situations. This is a great time for team members to ask clarifying questions if they need help understanding a policy change. It will enable you to update and make changes to the policy as needed and ensures that anyone on the team can answer questions from your patients about the policy clearly and concisely.
Reviewing and updating policies in your office can be daunting, but it is part of running a compliant and successful practice. If you want a copy of a one-page simple financial policy that can be used to set the stage for a simple, compliant financial system in your office, visit www. chirohealthusa. com/FROF.
Kristi Hudson is a certified professional compliance officer (CPCO). She serves as the Director of Business Relationships for ChiroHealthUSA where she has helped to educate DCs and CAs on establishing simple and compliant financial policies. You can contact Kristi at [email protected], 888-719-9990 or you can visit the ChiroHealthUSA website at www.chirohealthusa.com.
