Friday, April 27, 2018

Balance Billing and Air Medical Transport

Part Two

Welcome to Part Two of our blog series Balance Billing and Air Medical Transport. Last week, we looked at the historical aspect and defined the issue at hand. This week, we peer into the public perception, regulatory consequences, and make some suggestions on how to navigate the changing Balance Billing landscape.


Public Perception And Consequences

Because the financial implications of balance billing for air medical and other pre- and inter-hospital transports can be so significant, the concept of Balance Billing has come under a great deal of scrutiny in recent years. While our concern here is the medical transport industry, emergency departments, emergency physicians and other high-profile providers/suppliers are also under a great deal of scrutiny. Several national health care organizations, including one that provides emergency physicians services, have come under great pressure to end the practice. United Healthcare actually has a web page dedicated to educating consumers about the implications of balance billing performed by a specific organization. In certain circumstances, a single” high profile” case can bring tremendous outside pressure on Balance Billing practices.

More than 550,000 Patients in the U.S. use air ambulance services every year. The number of dedicated air ambulances in the U.S. has more than doubled in recent decades. Factors contributing to this growth include a decline in the availability of emergency services, changes in the delivery of health care in rural settings and the growing age of the population. There are also concerns that this proliferation has resulted in medically unnecessary use. In addition, the philosophy of many providers/suppliers has been to offer services as an “out of network” or “non-participating” entity. This means that the entity is not obligated to accept insurance payments as payment in full. One could argue that third party payments such as those offered by Medicare, Medicaid and many commercial insurance companies are not adequate to cover the cost of providing the services. The result is that many individuals find themselves with increasingly substantial financial responsibility after receiving these lifesaving services.

Legislative Action

There are a number of legislative authorities and regulatory agencies that are keenly aware of the impact of Balance Billing. A law was passed in North Dakota several years ago that requires 911 operators to contact “in-network” air medical providers first. The legislature in Montana has taken up the matter and is currently considering legislation that would place limits on billing practices for air medical transport. The unique application of the Airline Deregulation Act (ADA) in the air medical transport industry is a barrier to state efforts to regulate the industry and protect Patients. The ADA restricts the ability of states to regulate “rates, routes and structures” as it relates to using aircraft to provide services. What remains is an environment where providers/suppliers continue to offer these services and Patients may end up with responsibility for tremendous financial responsibility afterward. This impasse has brought great outside scrutiny to an industry that is already highly regulated and, in many cases, has put providers/suppliers in direct conflict with the Patients they serve.

Solutions And Strategies

In order to overcome the challenges faced by the medical transport industry, it is essential to have an organized approach to the Balanced Billing challenge. Providers/suppliers should be thoughtful and consistent in their approach. The following are strategies that Quick Med Claims suggests to our Clients:

  1. Follow Applicable Laws & RegulationsYou must always be aware of applicable laws and regulations that apply. This has become more challenging as more rules and regulations are promulgated in response to the public perception. Your organization should always adhere to applicable laws and regulations.
  2. Set Charges at a Reasonable LevelIn order to avoid scrutiny and negative perceptions on the part of key stakeholders, the provider/supplier should seek to set the charges for services at a reasonable level. One school of thought is to set charges in a fixed relationship to the cost of providing the services. In other words, it is advisable to understand the cost of providing the service and set the charges at that figure PLUS a reasonable mark up.
  3. Be Proactive in Educating the StakeholdersIt is advisable to educate the key stakeholders about the cost of providing the services, the methodology used to derive the charge structure and the policies that apply with respect to charity care. In addition to the Patients that are served, stakeholders include insurance companies, the government, employers and the communities served.
  4. Have Written Charity Care Guidelines and Follow ThemIt is imperative that every provider/supplier have a well-considered, written charity care policy that defines very specific criteria for how self pay balances are resolved. The policy should be followed consistently over time to avoid risk.
  5. Provide Fair and Reasonable Payment OptionsEach provider/supplier should have a specific approach to offering reasonable payment terms for Patients. As the Patient responsibility portion of air medical claims continue to grow, it will be important for the provider/supplier to offer fair and reasonable options for payment.

Wrapping Up

It is often difficult to find a balance between providing these important and valuable services to the communities we serve and maintaining our financial viability as a medical transport organization. The cost of providing the services continues to rise and the financial burden for our Patients continues to rise. Be proactive in your approach to Balance Billing and resolving financial responsibility for the services that you provide.

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