Medical Debt Collection

Medical Debt Collection

Good faith estimates and medical debt collection will likely impact your practice and your patients in 2023.

The Medical Debt Relief Act of  2023
Changes to laws and mandates in 2023 can help patients reduce or avoid medical debt. Beginning Jan. 1, 2023, medical debts less than $500 no longer appear on credit reports.

Medical Debt Collection
Recent developments signal that medical debt collection is going to become even more difficult for physician practices. Implementing successful in-house collection programs and collecting from all available payment sources should be a priority for practices and will minimize the number of accounts aging to bad debt status. To improve your in-house collections, we recommend the following steps:

  1. Improve collection of patient information and payments up front.
    Preregister patients by collecting demographic and insurance information over the phone or online when they make an appointment. Verify insurance information before the appointment and collect copays, deductibles and outstanding balances when the patient checks in.
  2. Train your front desk staff on how to provide excellent customer service – while still asking for payment.
    The College’s 15-minute educational module “Steps for Successful Front Desk Training” is part of our free Allergy Office Essentials package and provides your staff with helpful tips on maintaining appropriate body language and verbal language skills, collecting payment, and more.
  3. Consider implementing a credit card on file program.
    A credit card on file policy involves safely and securely storing your patients’ credit card information electronically. The College’s 15-minute educational module, “Credit Card on File” will explain how to implement this program, and includes training for staff, tactics for communicating the new policy to patients, and more. You can find this educational module in the Allergy Office Essentials package.

Good Faith Estimates
Good faith estimates (GFE) for people who self-pay must include projected costs from the main facility or provider. Eventually, the GFE requirement may extend this requirement to care reasonably expected to be furnished in connection with services provided by allergists.

The Centers for Medicare and Medicaid Services (CMS) announced in guidance that it will continue to delay enforcing the convening/co-provider GFE requirement of the No Surprises Act (NSA) as well as the NSA’s Advanced Explanation of Benefits (AEOB) requirement because there were still many operational aspects of those requirements that need to be resolved.

CMS will instead issue a Request for Information (RFI) to solicit public input. CMS is extending its enforcement delay indefinitely pending the issuance of implementing regulations.

The enforcement delay does not impact the portion of the GFE which took effect on Jan. 1, 2022 requiring health care providers and facilities to furnish uninsured or self-pay patients with a GFE for their facility either upon request or upon scheduling care. The GFE only needs to include the primary item or service for which the patient is requesting or scheduling care. More details on NSA requirements for allergist are available in the College’s Risk and Compliance Toolkit.

The two provisions subject to this enforcement delay are:

  • Convening/co-provider GFEs. The NSA statute requires GFEs to include care reasonably expected to be furnished in connection to the primary item or service. Separately scheduled services are not included as connected care. Patients can request separate GFEs for separately scheduled services.
  • AEOBs. The Advanced Explanation of Benefits (AEOB) provision requires convening providers to send the completed GFE to a patient’s health plan so the health plan can then furnish the patient with an AEOB that lists the GFE price and the in-network price side-by-side for the patient to compare.

CMS decided to delay enforcement of the GFE connected care and the AEOB requirements because it acknowledges how administratively burdensome it will be for providers and health plans to facilitate the communications necessary to satisfy these provisions. The delay gives CMS more time to develop the technical standards necessary to facilitate these two provisions.

CMS also published new FAQs about GFE implementation. The FAQs explain how to include items or services that will not be billed to the patient in GFEs. The guidance also provides clarifications on how sliding fee schedules can comply with the GFE requirement.

For more tips on how to improve practice collections, view the College’s Collections Toolkit.