The American Addiction Treatment Association (AATA) published the Patient Financial Responsibility Toolkit to answer burning questions that are troubling the addiction treatment industry. Insurers are accusing providers and programs of fraud and abuse when they offer discounts and waive fees. What’s legal and what’s abusive? What approach should programs and professionals take to avoid a world of trouble in mishandling patient financial responsibility?
When addiction programs and professionals market and promote addiction treatment or recovery services, limited patient and family financial resources are a major challenge. For many, the solution of offering discounts, fee waivers, and scholarships seem like an obvious solution: if people don’t have resources, why don’t we just charge as little as they can afford? The problem is that insurers and health plans treat these as illegal inducements or kickbacks and interference with patient insurance contracts.
The Patient Financial Responsibility Toolkit is designed to educate providers and program professionals about the appropriate way to handle the confusing and risky issues around patient financial responsibility, including guidance and model policies, processes, and talking points for staff involved in discussing discounts. Addiction treatment staff and marketing professionals should be informed about the proper approach to offering incentives over the phone or in person to potential patients.
“AATA has broken new ground with the Patient Financial Responsibility Toolkit,” said Harry Nelson, Founding Board Chair of AATA. “This is the first resource of its kind in the addiction treatment industry. We’re seeing a crackdown nationwide on discounting and other incentives to promote particular treatment centers. Programs need to review their business practices carefully to avoid being swept into these investigations. It’s not just about the policies and procedures; the entire staff needs to be trained on how to talk to patients on these complicated issues. The Toolkit makes clear where the lines are and are intended help programs meet the expectations of payers.”
“The biggest issue we see is looking for shortcuts,” said Max Sirianni, General Counsel for Infinity Behavioral Health Services. “There are (almost) no shortcuts in billing. Providing quality clinical care, clearly documenting services provided, and adhering to payer guidelines are the foundational aspects of a healthy revenue cycle. Those are not always easy, but if you have those in place, you will succeed in the long run. The irony in these practices is that most providers believe they yield greater returns, but the truth is that these end up being the pain-points prompting medical record requests, denials, refund requests and even audits with special investigation units. Providers also tend to underestimate the value of their medical records, which are playing a bigger and bigger role in determining a provider's worth. Not only do medical records rarely meet payers' expectations, but providers are rarely aware of what those expectations really are.”
It is paramount for addiction treatment staff to be trained for handling patient financial responsibility. “There are different layers of compliance that providers should be concerned with when it comes to financial arrangements. To ensure compliance with the law and also to meet the expectations of commercial health insurers, it is important to implement sound policies and procedures which govern the financial arrangements made between providers and patients. Failure to formalize these processes with diligence may result in conflict with payers if patients are not required to pay their portion; or even worse, conflict with the law if a provider is engaged in illegal forms of patient inducement. The most important thing for anyone in a role like this is to always ensure that everything about the services you are billing is a 100% accurate representation of the services that are being provided,” Sirianni explained. “It should be assumed that every single patient's chart will be reviewed at some point. It is important that each patient's chart tells the story of their treatment without any questions left unanswered. This means more than matching CPT codes with a treatment plan. This means that providers understand what procedure codes represent and that they understand what payers expect at different levels of care. Unfortunately, behavioral healthcare is a very young industry and simply asking friends for advice is not sufficient. I would encourage anyone in such a role to educate themselves. The great thing about payers' expectations and level of care guidelines is that they are free and public resources. Do your own research and make sure you understand the services that you are providing. If you are billing appropriately for the services you are providing, you are more likely to endure long-term success than a provider looking for the right combination of procedure codes to get paid as much as possible.”
The Patient Financial Responsibility Toolkit is available online as a download. “AATA wants addiction treatment professionals to avoid a crisis and remain compliant with the latest regulations,” Nelson added. “Since launch, we’ve received great feedback on the Patient Financial Responsibility Toolkit from the addiction and recovery treatment industry. This may be the best way to help providers because the toolkit is accessible day or night. We encourage providers to seek legal advice and work with an attorney in writing specific program policies while also offering recommendations and strategies for reducing the risk of fraud or abuse.”
AATA is currently working on additional toolkits to help guide addiction treatment and recovery professionals through the process of compliancy. For more information on AATA membership, events or the Toolkit, visit www.addiction-tx.com or call (888) 958-2282.