Is it a case of closing the barn door after the horse has already vanished? Or can there be some meaningful movement towards accepted debt collection standards for healthcare collections? Those are the questions insidePatientFinance’s Evan J. Albright looks at in his post over on our Forbes.com blog: Hospitals, Debt Collectors Rush to Create Standards for Collecting Patient Debt:
The proposed guidelines are currently under review by the general membership of HFMA and ACA International. Later this month the task force will review all the comments made on the proposed guidelines, update them, and then send the guidelines to the respective boards of those organizations for ratification. Unlike the actions in Congress or by the IRS, these guidelines will simply be that–a list of best practices that a medical provider or its partners can either accept or reject.
The guidelines at question were covered over on insideARM.com: ACA, HFMA Seek Input on Medical Debt Collection Standards. Spefically:
- Allowing patients 120 days to pay bill before reporting to a credit agency. The proposed IRS 501(r) regulations for nonprofit hospitals defining “extraordinary collection actions” will require this, should they be enacted. The guideline also mirrors proposed changes to the Fair Debt Collection Practices Act (FDCPA) in a bill introduced in the U.S. House in late May. However the proposed guidelines differ from the proposed IRS regulations in that there is no second 120-day period to allow a patient to file a financial assistance application.
- Removing paid medical debt from credit reports within 45 days. This is a cornerstone of the proposed Medical Debt Responsibility Act currently working its way through Congress. The task force is recommending that this be considered a best practice, and that to make it logistically possible providers, their credit agency partners, and credit bureaus conduct regular reconciliations of patient accounts.
- Standardizing the “collection process clock.” The proposed guidelines recommend that the collection process clock starts at first statement date from provider’s system.
- Requiring collection partners to adhere to provider’s policies and procedures. All vendors and partners involved in the collections workflow need to adhere to the provider’s policies and procedures. In addition, “policies related to extraordinary collections activity (ECAs) (as defined by the IRS—i.e. liens, credit reporting, lawsuits, wage garnishments, or sale of debt) are board approved, and communicated to and practiced by collection agencies.”
- Requiring providers and partners to regularly reconcile accounts. “Regular reconciliations should occur between provider system and business affiliate system.”
- Tracking and reporting patient complaints. “All business affiliates involved in account resolution activities are required to report patient complaints.”
Will the guidelines have any effect? Only with committed focus. Guidelines can be a popular face to present, but with no enforcement, they soon become meaningless. There are some strong ideas that could address a lot of the concerns on both sides — patient and provider — of the equation. Let’s hope they don’t get lost in the noise.