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Access Management JournalThe Official Journal of the National Association of Healthcare Access Management Volume 40, Number 1
NAHAM 42nd Annual Conference Set to Rock ‘The Big Easy’
Striving for One Call: Achieving Excellence in Pre-Access Operations
ICD-10: Life in the Post-Transition World
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Table of Contents
Access Management JournalThe Official Journal of the National Association of Healthcare Access Management
NAHAM BOARD OF DIRECTORS Yvonne Chase, MBA, CHAM, FHAM, PresidentBrenda Sauer, CHAM, FHAM Immediate Past
President and 2015 Conference ChairElizabeth Reason, MSA, CHAM, Vice PresidentRebecca Holman, CHAM, SecretaryCatherine Pallozzi, CHAM, Treasurer
COMMITTEE CHAIRSCertification Commission Chair Annemarie Mariani, CHAMMembership Committee Chair Pam Carlisle, CHAM, FHAMPolicy Development & Government Relations Committee Chair Michael Sciarabba, FHAMSpecial Projects Committee Chair Eston Allison, CHAMPublications & Communications Committee Chair Jeffrey Brossard, BSHA, CHAMEducation Committee Chair Terri Cheeks-Rice, CHAMIndustry Standards Committee Chair Paul Shorrosh, CHAM
REGIONAL DELEGATESExecutive Delegate and Southwest Regional Delegate Patricia Consolver, CHAM, FHAMCentral Regional Delegate Andrew Wooten, CHAMMidwest Regional Delegate Nicole Fountain, CHAMSoutheast Regional Delegate Christopher Horton, CHAMNortheast Regional Delegate Teri Bell, CHAMNorthwest Regional Delegate Bernie Andreotti, CHAM
EX-OFFICIONAHAM Ambassador Maxine Wilson, CHAMExecutive Director Mike Copps
Jeffrey Brossard, BSHA, CHAM, Committee Chair
Vicki DunlapMillie HastApril HokeCheryl MonahanWendy Maria Roach, CHAMCarla SchultJane Severs, MHA, FACHE, CHAMCharlene Smith Judi StecklerSarah Webb-King
Volume 40, Number 1
ACCESS MANAGEMENT JOURNAL STAFF
PublisherMike CoppsEditorDennis Coyle
Associate EditorKelly Mantick
Access Management Journal(ISSN 0894-1068) is published by:NAHAM2025 M Street NW, Suite 800Washington, DC 20036-3309Telephone: (202) 367-1125Fax: (202) 367-2125
© Copyright 2016, National Association of Healthcare Access Management.Indexed in Hospital Literature Index, produced by the American Hospital Association in cooperation with the National Library of Medicine.The printed edition of Access Management Journal is not to be copied, in whole or in part, without prior written consent of the managing editor. For a fee, you can obtain additional copies of the printed edition by contacting NAHAM at the address provided.The National Association of Healthcare Access Management (NAHAM) was established in 1974 to promote professional recognition and provide educational resources for the Patient Access Services field.The Access Management Journal subscription is an included NAHAM member benefit. NAHAM 2016 membership dues are $195 for Full Members, $1,500 for Business Partner Members and $60 for Associate Members. For more information, visit www.naham.org.
PUBLICATIONS AND COMMUNICATIONS COMMITTEE
Feature Articles
6 NAHAM 42nd Annual Conference Set to Rock ‘The Big Easy’
20 Striving for One Call: Achieving Excellence in Pre-Access OperationsBy Michael Sciarabba, CHAM
22 ICD-10: Life in the Post-Transition WorldBy Christina M. Janus, MBA, RHIA, CHAM
Departments
4 President’s Letter
24 Association News
26 Advocacy Update
28 Discussion Guide
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Last year was very busy for those in the healthcare profession. Many of us had numerous projects on our plates as well as an electronic medical record (EMR) conversion underway. As I reflect on 2015, I can’t help but think of all the people we helped and the lives we touched at my facility. I’m sure you feel the same way.
We really do make a significant difference as healthcare professionals. Not only do we impact individuals, we also impact the entire communities we serve. This is my true passion, and I feel blessed to work in a field I love each day.
Healthcare is a fast-paced environment with such a changing landscape, and you really never experience the same day twice. So let’s look at 2016 and the opportunities that lie ahead for us. Are we looking for ways to improve our revenue cycle management? With cash flows declining, margins tightening and bad debt increasing, maintaining a steady income is crucial. As NAHAM members, you have access to tools that can help.
NAHAM AccessKeys® Help Drive ChangeThe NAHAM AccessKeys® is a series of equations designed exclusively for Patient Access professionals to measure how well front-end departments and staff are doing across six domains. You can utilize these data points to drive change and
NAHAM Offers Two Great Opportunities in 2016
President’s Letter
manage process improvement imitatives. Remember, you can’t manage what you don’t measure. Using the data to identify trends is invaluable for gaining insights into how to improve your revenue cycle. It can also help engage staff in the process and enable them to be active participants in process improvement.
NAHAM Annual Conference is Set to Wow AttendeesWith a new year comes a new conference. This year, the NAHAM 42nd Annual Conference will be held in New Orleans, Louisiana, May 24-27. It will be a conference with so many exciting opportunities, including a president’s reception, opening general session, learning labs, NAHAM committee meetings and our closing session. Attending the annual conference is not only a great networking opportunity, but the educational sessions will provide attendees with innovative ideas to launch at their facilities.
And let’s not forget this conference is in the one and only New Orleans. For those who have not visited New Orleans, it is a wonderful destination. From the historic French Quarter to Café Du Monde, jazz music and Bourbon Street, the lively city has something for everyone.
The annual conference committee has done a great job planning for an awesome event. I hope I will see you all there. I always leave the conference with a new sense of excitement and refreshed to take on some new challenges, and I know you will as well!
Yvonne A. Chase, MBA, CHAM, FHAMPresident, NAHAM
Members are encouraged to take advantage of The
NAHAM AccessKeys® and join fellow Patient Access
professionals at the NAHAM 42nd Annual Conference.
May 24 - 27, 2016 l New Orleans, Louisiana
annual conferenceNAHAM 42nd
the multiple faces of the patient experience
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This year, NAHAM’s Annual Conference is celebrating “The Multiple Faces of the Patient Experience” with a packed line-up of educational sessions, speakers, exhibitors and fun activities in host city New Orleans. As Patient Access managers, the patient experience starts with you, and it’s essential to ensure that patients’ journeys through the healthcare system—from the moment they enter the front door to when they receive their final bill—is flawless.
At the conference, attendees will learn from experts on how to streamline processes, hire quality frontline employees and even how to harness the power of laughter.
Whether you’re looking to find innovative new ways to approach lingering challenges or you’re interested in learning what is new
in the world of Patient Access, there are sessions to attend and peers to connect with who will help you along your Patient Access journey.
And, beyond the conference, “let the good times roll” in “America’s most interesting city”: New Orleans! Enjoy the old-world charm of this famous city, listen to jazz music, peruse the Royal Street’s antique shops and snack on a beignet at Café du Monde. The opportunities and experiences awaiting you in New Orleans are endless.
Laugh and Learn at NAHAM’s General SessionsBookending the conference, the opening and closing general sessions serve to inspire new ways of thinking or looking at a particular situation. The presenters lined up for
the conference’s general sessions are sure to do just that.
To kick off the conference on the morning of May 25, Brad Nieder, MD, CSP, will blend healthcare humor with wellness advice and an uplifting message during his keynote “Laughter Is the Best Medicine.” Entertaining and inspiring, he will explain the actual science behind the well-known phrase “laughter is the best medicine,” revealing benefits such as managing pain, enhancing immune system function, reducing stress and more.
Closing the conference on May 27, Jay Kaplan, MD, will present
“Innovative Approaches to Improve the Patient Experience.” Kaplan, a veteran in the healthcare industry,
currently serves as the medical director of the Studer Group, as well as a partner and past service excellence director of CEP America. With many more accolades to his name, don’t miss this opportunity to tap into Kaplan’s expertise to find new approaches for managing the patient experience.
Are You Ready for the NAHAM 42nd Annual Conference?
Make a Commitment to Your FutureWhile much of the work Patient Access managers perform every day is based on serving other people—employees, executives and patients—attending the NAHAM Annual Conference is an opportunity for you to focus on your own professional development and career. When you register for the conference, you are solidifying this commitment to invest in your future.
For more information and to register, visit the NAHAM website at www.naham.org. To take that personal investment to the next level, sign up for the onsite CHAA and CHAM Examinations by May 2. For registration questions or assistance, please contact [email protected] or (202) 367-1173.
Brad Nieder
Jay Kaplan
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Plan Your Conference Experience with the Schedule-at-a-Glance
Tuesday, May 24
9:00 a.m. – 11:30 a.m. CHAM/CHAA Examinations
11:00 a.m. – 6:30 p.m. Registration
12:00 p.m. – 2:30 p.m. NAHAM University
2:45 p.m. – 5:00 p.m. Pre-Conference Symposium: Point of Service Collections
Pre-Conference Symposium: Patient Identity
5:30 p.m. – 6:30 p.m. NAHAM First Timer and New Member Reception, Hosted by the NAHAM President
Wednesday, May 25
6:30 a.m. Wake-up Walk
7:30 a.m. – 6:00 p.m. Registration
7:45 a.m. – 8:45 a.m. Membership Meeting
9:00 a.m. – 10:30 a.m. Opening General Session: Laughter Is the Best Medicine
10:30 a.m. – 11:30 a.m. Regional Meetings
11:45 a.m. – 1:00 p.m. Industry-Sponsored Symposia/Lunch
1:15 p.m. – 2:30 p.m. Learning Lab Series 1
2:45 p.m. – 3:45 p.m. User Groups
4:15 p.m. – 5:15 p.m. Learning Lab Series 2
5:15 p.m. – 6:30 p.m. Stress-free Zone
6:15 p.m. – 9:00 p.m. Welcome Reception in Access Solutions Showcase
Thursday, May 26
6:30 a.m. Wake-up Walk
7:30 a.m. – 4:00 p.m. Registration
7:30 a.m. – 8:45 a.m. Industry-Sponsored Symposia/Breakfast
9:00 a.m. – 11:00 a.m. General Session: The Patient Experience
11:15 a.m. – 12:30 p.m. Learning Lab Series 3
12:30 p.m. – 2:45 p.m. Lunch in Access Solutions Showcase
3:00 p.m. – 4:15 p.m. Learning Lab Series 4
4:30 p.m. – 5:30 p.m. NAHAM Committee Meetings
5:30 p.m. – 6:30 p.m. NAHAM Happy Hour
Friday, May 27
6:30 a.m. Wake-up Walk
7:30 a.m. – 2:00 p.m. Registration
7:30 a.m. – 9:30 a.m. Breakfast and Prize Drawings in Access Solutions Showcase
9:45 a.m. – 11:00 a.m. Learning Lab Series 5: "Best Of" Series
11:15 a.m. – 12:45 p.m. Closing General Session: Innovative Approaches to Improve the Patient Experience
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Out and About in New OrleansSheraton New Orleans will play host to this year’s NAHAM Annual Conference, and you couldn’t ask for a better place to stay. With modern rooms and suites complete with Sheraton Signature beds, attendees will find the hotel a great place to rest and recharge after an action-packed day. Plus, the Sheraton Club offers a number of perks, such as personalized club managers and free breakfast and hors d’oeuvres in the Club Lounge. From beignets to cocktails, the Sheraton New Orleans has it all.
Residing on one of the most celebrated parade routes in the world, the Sheraton is a mere two blocks from the French Quarter, Bourbon Street, Riverwalk and Warehouse District. From this ideal spot, attendees can walk through the historic French Quarter to enjoy jazz clubs, museums, antique shops, unique architecture and galleries. The hotel is also a quick streetcar ride away from the Garden District, where you can view elegant mansions with expansive gardens dating back to as early as 1803. Plus, the steamboat offers a variety of entertainment options and interesting stops.
In addition to the various amenities and nearby attractions, booking at the Sheraton ensures that you will receive the discounted, NAHAM-negotiated room rate. Don’t forget to book your room early to ensure your spot!
Reserve Your Room TodayPlease reserve your room at the Sheraton New Orleans (500 Canal Street) as soon as you can to guarantee your room at NAHAM’s negotiated rate. The discounted rates are as follows:
• $199 single or double
• $239 for Club Level (by request)
• $25 for additional adult over two
These rates are available for May 19-31. Note that rates are exclusive of sales and occupancy taxes.
For more information, visit www.naham.org or make your reservation via phone by calling one of these numbers:
Reservations Toll Free: (888) 627-7033
Reservations Local Phone: (504) 525-2500
Safe Travels to New OrleansAre you itching to get going to the NAHAM Annual Conference already? Here a few transportation tips to remember when planning your trip:
�� The Sheraton is a 25-minute drive from the Louis Armstrong International Airport (MSY).
�� Valet parking is available at the Sheraton, and all vehicles are secured in a covered garage near to the hotel. The overnight guest rate is $40 plus tax.
�� A range of rental car companies are available at the Louis Armstrong International Airport, including Hertz, Enterprise, Budget and more. For rental reservations, please contact the companies directly.
�� For taxi service, follow signs in the airport for ground transportation and taxis. Taxis are available outside of baggage claim and the average fare to the Sheraton New Orleans is $36 for one or two guests, $15 per person for three or more guests.
�� Reserve a shared ride service between the Sheraton New Orleans and Louis Armstrong International Airport through New Orleans Airport Shuttle. Rates are $24 per person one way and $44 per person round trip. Please call (504) 522-3500 for information or make reservations online at least 24 hours prior to your flight departure time at: Sheraton New Orleans Hotel Airport Shuttle.
Visit www.naham.org for more details.
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10The front-end Patient Access process of seeking coverage information—whether you call it prior authorization, pre-service, prior approval, precertification, preauthorization or the shortened term “pre-auth”—can be very stressful and fraught with challenges and inefficiencies.
An inefficient workflow often leads to denials due to missing prior authorizations; uncertainty surrounding prior authorization requirements; manual, time-consuming workload for staff; and ultimately dissatisfied (and in many cases stressed) patients.
Pre-auth teams are continually challenged to strike a balance of fiscal responsibility while providing the patient compassionate care and financial guidance. Preauthorization does not
Ochsner is driven by its commitment to serve, heal, lead, educate and innovate, and that passion is shared with every staff person who passes through its doors.
Ochsner’s centralized prior authorization team, located in New Orleans, supports 13 hospital locations and more than 50 clinics. Comprising of 102 full-time employees, which includes 15 licensed practical nurses (LPNs) and registered nurses (RNs), the team cleared more than 450,000 cases in 2015.
Workflow consisted of manual processes via phone and fax, with the ensuing “follow up, follow up and more follow up,” as well as countless non-value touches. All of these touches negatively impacted accounts receivable and patient financial education/information lead days.
De-stressing Patient Access In order to live up to its organizational commitments,
Pump up the Pre-Auth Process to Avoid Financial StressBy Brandon McCord, M.A., MBA, MHI
Session Title: How to Alleviate Financial Stress so Patients Can Focus on Healing
Presenters: Brandon McCord, M.A., MBA, MHI, Pre-Service Director, Ochsner Health System; and Jim Czajkowski, BA, Regional Vice President, Clinical Solutions, Experian Health
Learning Lab: Series 3 and 5
Date/Time: May 26, 11:15 a.m.-12:30 p.m.; May 27, 9:45-11:15 a.m.
Pre-auth teams are continually challenged to strike a
balance of fiscal responsibility while providing the patient
compassionate care and financial guidance.
guarantee that a health insurance plan will cover the cost, and the last thing patients need is the stress of not knowing their potential payment obligations.
BackgroundOchsner Health System has been providing high-quality clinical and hospital patient care to Louisiana residents since 1942. Its healthcare family comprises of more than 17,000 employees and more than 2,700 affiliated physicians.
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Ochsner set goals to streamline its authorization processes and make teams more efficient, with the goal of de-stressing employees and patients alike. Starting with surgery and using Lean methods to evaluate workflows, Ochsner implemented an online, real-time authorization management service that streamlines and facilitates the prior authorization inquiry and submission processes. Inquiries are automated and take place behind the scenes without user intervention. Submissions guide the user through the workflow, auto-filling all of the payer data and prompting the user only if manual intervention is required. This measure increased efficiency and enabled staff to spend more
time with patients to discuss estimated liability and financial responsibility as well as provide them with payment plan options.
Ochsner’s real-time authorization management tool, along with its Lean mentality, is helping staff work together to improve Patient Access processes, spending less
time following up with payers and focusing more on what’s most important—patients. Learn more about how Ochsner restructured its prior authorization inquiry and submission processes during the session “How to Alleviate Financial Stress So Patients Can Focus on Healing” at the NAHAM Annual Conference. l
In order to live up to its organizational commitments, Oschner
Health System set goals to streamline its authorization
process and make teams more efficient, with the goal of de-
stressing employees and patients alike.
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training for revenue cycle applications from early stage planning (before UAMS had even decided on Epic) through full implementation.
Sarah Webb-King, B.S., CHAM, defines simulation training as the use of standardized patients (trained actors) and/or high-definition mannequins to mimic actual patients in a replicated clinic or inpatient environment. During the presentation, she will describe the benefits to end users and lessons learned by the UAMS team. She will outline why UAMS decided to use simulation for access/revenue education and how UAMS anticipated simulation training would impact its end users in a meaningful, patient-centric manner.
The presentation will cover the process for creating real-life scenarios in revenue cycle applications and the logistics involved in restructuring the training environments, modifying lesson plans and leveraging
The University of Arkansas for Medical Sciences (UAMS) in Little Rock is the only comprehensive academic health sciences university in Arkansas. UAMS has 434 patient beds, including 330 adult beds, 30 adult psychiatric beds, 10 pediatric psychiatric beds and 64 bassinets. UAMS employs more than 10,000 employees, including about 1,000 physicians, 782 residents and 2,890 students throughout seven colleges.
During implementation, 6,743 of those employees attended at least one Epic training class. UAMS implemented Epic in a pop-bang roll out. It went live with 17 primary ambulatory clinics, scheduling and professional billing in August 2013. In May 2014, the inpatient units, remaining ambulatory specialty clinics, radiology, lab and hospital billing office went live. UAMS implemented an enterprise of 17 Epic applications
Leverage Simulation Training for Revenue Cycle ApplicationsBy Sarah Webb-King, B.S., CHAM
Session Title: Welcome Aboard UAMS Simulation Flight 4301: Non-stop Service to Patient-centric Care
Presenters: Sarah Webb-King, B.S., CHAM; Epic Certified in Cadence/ Prelude/Grand Central (ADT)/Referrals/Welcome applications
Learning Lab: Series 1 and 5
Date/Time: May 25, 1:15-2:30 p.m.; May 27, 9:45-11 a.m.
(ADT, Anesthesia, ASAP, Beacon, Beaker, Cadence/Prelude, EpicCare Ambulatory, EpicCare Inpatient [Clinical Documentation, CPOE and Stork], HIM, OpTime, Radiant, Resolute [Hospital Billing and Professional Billing], and Willow [Inpatient and Ambulatory]).
The presentation, "Welcome Aboard UAMS Simulation Flight 4301: Non-stop Service to Patient-centric Care," will illustrate UAMS’ philosophy around simulation
Sarah Webb-King, B.S., CHAM, defines simulation training
as the use of standardized patients (trained actors) and/or
high-definition mannequins to mimic actual patients in a
replicated clinic or inpatient environment.
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to simulation training for clinical and non-clinical applications.
�� Participants will be able to reference successes and shortcomings of an enterprise simulation training project.
Deliverables include:
�� Participants will have the opportunity to take home actual simulation scenarios that were created and used by instructional designers during a "big bang" implementation.
credentialed trainers and super users in order to accommodate all of the identified end users during go-live training. Attendees will also learn about the challenges faced during the training process, strategies that were successful and some that were not as successful. Participants will be able to learn from UAMS’ experiences and take home valuable information for creating their own simulation training. Furthermore, ideas for future post-implementation of simulation training, including introducing interdisciplinary simulation training into refresher classes will also be discussed.
Some of the highlights from the presentation will include:
�� How to use feedback and results from simulation training to adjust classroom lesson plans on an ongoing presentation prior to the go live.
�� How simulation training allowed UAMS to identify physical limitations of equipment and create solutions before go live.
�� How simulation training allowed UAMS to evaluate different workflows and determine the most efficient standard operating procedure.
�� How simulation training allowed UAMS to better prepare super users for at-the-elbow support by allowing them insight into common errors that were exposed during simulation.
�� Introduction of real-life scenarios that gave staff the platform to explore their personal integration of the electronic health record (EHR) into their everyday work prior to go live.
�� Benefits of allowing registrars to ascertain increased comfort level with the EHR so that patient care would be the focus at go live.
�� Benefits of allowing registrars to develop muscle memory around performing tasks while in the presence of a patient and using a new EHR.
�� Benefits of practicing with device integration before go live.
�� How to incorporate core values of patient- and family-centered care into training.
�� How simulation training allowed UAMS to help front desk end users bridge the gap between classroom and clinic by enabling schedulers and registration staff to practice in Epic amid a myriad of distractions such as phone calls from other patients during check in, coworkers asking questions during scheduling, etc.
�� Data on how simulation training expedited learning curves.
Learning objectives include:
�� Participants will discuss the benefits of simulation training within their organizations.
�� Participants will be able to incorporate different approaches
Join Webb-King for an Epic journey through the exotic world of simulation training. Her pre-flight checklist will prepare participants for a comfortable implementation of simulation training. She will discuss the motivation for simulation training and how UAMS felt it would improve patient-centric outcomes.
As Patient Access managers set out to explore unknown worlds, Webb-King will discuss how UAMS created scenarios, avoided some turbulence and arrived safely at its destination. Upon arrival, Webb-King will discuss creative solutions to survive the ever-changing actual classroom environment and how to leverage Sherpas to soothe the native users. l
Join Webb-King for an Epic journey through the exotic
world of simulation training. Her pre-flight checklist will
prepare participants for a comfortable implementation of
simulation training.
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different areas within the team. The council included at least one member from each of the facilities, including outpatient, ED/urgent care, analysts, daytime team, weekend/night team, etc. Children’s Mercy wanted to ensure it captured the voices from varying shifts and locations.
After some additional research, members of the supervisor team rolled out the idea to staff and excitement grew to become aparticipant. Fifteen people in non-leadership roles were selected. Those involved were responsible for collaborating with leadership on the following:
�� Providing feedback on a variety of topics, including recent changes and how they impacted their areas, staff morale, etc., while advising if further information was needed when changes take place,
�� Testing new technology,
�� Assisting with updating processes and procedures,
�� Planning team-building events and
�� Assisting with organizing Patient Access Week activities.
The goal was to bring a better, stronger and more honest voice to represent those who are impacted the most by day-to-day decisions as well as enable leadership to make more meaningful changes.
Have you ever seen some of your star employees dim over time? Does your organization find it difficult to keep employees engaged and get them to “buy in” to new process changes? Are you utilizing each member of your team to their full potential?
The admissions team at Children’s Mercy in Kansas City, Missouri, consists of more than 200 members. Each year, a staff viewpoint survey solicits feedback regarding leadership, teamwork, safety, etc. throughout the organization. After reviewing the results, four key areas for improvement were identified: transparency, recognition, challenging work and an understanding of the decision-making process.
The first step Children’s Mercy took in generating new ways for improvement in the aforementioned areas was to reach out to similarly sized departments. The results indicated that if Children’s Mercy wanted these
Are you utilizing each
member of your team to
their full potential?
Patient Access Council at Children’s Mercy Positively Transforms Its StaffBy Savannah Lacy
Session Title: Patient Access Council: Empowering Staff through Collaboration
Presenters: Heather Sloan, Admissions Manager, Children’s Mercy; and Savannah Lacy, Children’s Mercy
Learning Lab: Series 1
Date/Time: May 25, 1:15-2:30 p.m,
improvements to truly impact the frontline team members, it should focus on working with the experts: the admissions team that completed the survey and can offer valuable feedback on where leadership specifically needed to improve.
Working with such a large team can get messy; you might have too many hands in the pot or too many differing opinions, and it’s nearly impossible for everyone to meet at the same time. The response at Children’s Mercy: Create a Patient Access council comprising of members from
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The members of this team are learning how to self-govern their meetings and appropriately communicate higher-level informaiton to their peers. They get an inside look at the decision making their supervisors and managers face on a day-to-day basis and how it impacts everyone.
Speakers Heather Sloan and Savannah Lacy invite you to experience their journey in creating and implementing the Patient Access Council at Children’s Mercy.
Whether you have a staff of 10 or 200, Sloan and Lacy encourage you to learn from their successes and challenges to build your own council. They strongly believe this approach improves overall communication, increases transparency, challenges the skillsets of your untapped resources and builds better leaders for your department’s future. l
As the team continued to meet, Children’s Mercy has encountered numerous successes and faced surmountable challenges. The Children’s Mercy admissions team is made up of many untapped resources, and it is learning how to channel the staff ’s various creative and technical abilities through different projects to keep the team feeling engaged and challenged in areas they find more enjoyable. This council is instrumental in
assisting leadership communicate changes to all staff members, becoming a “champion of change” to peers in the process.
As email has become a tool for mass communication, participants are able to increase transparency by providing an additional voice to their coworkers to explain why a change has taken place. This is a refreshing form of communication as it can aid leadership in verifying messages have been received.
Speakers Heather Sloan and Savannah Lacy invite you to
experience their journey in creating and implementing the
Patient Access Council at Children’s Mercy. Whether you
have a staff of 10 or 200, Sloan and Lacy encourage you to
learn from their successes and challenges in how to build
your own council.
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revenue cycle spectrum of roles and responsibilities,” said Shellie Zuroske, CRCR, revenue cycle trainer at OSF Saint Anthony Medical Center. Particularly through her time as a contract managed care analyst, she quickly learned the importance of providing Patient Access with the educational tools required to ensure they have the confidence and knowledge required to perform complex tasks.
While managers understandably have high expectations for Patient Access associates to drive the process of producing a clean claim, Zuroske recognized that Saint Anthony Medical Center never truly defined for its frontline associates what a clean claim means or why it is so important in maintaining financial integrity for the organization—at least not in a way that was meaningful and had sticking power.
Onboard training for most Patient Access professionals includes completing a relatively short curriculum that probably covers a few
Defining the roles and responsibilities of the positions throughout the revenue cycle is a difficult task. When screening for new employees, you may find that you start with a wish list of preferred qualifications. You search for individuals that have good computer skills, the ability to communicate effectively and are capable of learning quickly. As you sift through applicants with a desperate need to fill a shift, you may find yourself compromising and crossing out items on your wish list in order to expedite the hiring process. Given the high emphasis on patient experience and the need to have customer-oriented people in your access roles, you may find yourself choosing personality and attitude over knowledge.
When great candidates come in lacking the necessary knowledge they need to effectively and efficiently serve your patients, a good training
Empowering Patient Access Through EducationBy Shellie Zuroske, CRCR
When those great candidates come in lacking the necessary
knowledge they need to effectively and efficiently serve your
patients, a good training program is essential to fill in the
gaps and equip new employees with those learnable skills.
Session Title: Extensive New Hire Education Program: Producing Positive Results
Presenter: Shellie Zuroske, CRCR, Revenue Cycle Trainer, OSF Saint Anthony Medical Center
Learning Lab: Series 4
Date/Time: May 26, 3-4 p.m.
program is essential to fill in the gaps and equip new employees with those learnable skills. You hire these individuals with the assumption they will grasp basic concepts and learn rules and regulations while on the job or by shadowing veteran employees. However, placing these employees into the sea of highly educated clinical staff usually leaves a new hire feeling nervous and inferior, which can lead to employee dissatisfaction and increased turnover rates.
“During my 27-year tenure in healthcare, I have covered the
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basic concepts and an orientation to the electronic health record. This is likely followed by a week or two of on-the-job shadowing. Most Patient Access professionals probably agree that this approach isn’t nearly enough, but who has the time or resources to do more?
As healthcare quickly evolves, revenue cycle teams continue to work proactively to capture revenue and reduce denial rates by adding workflows to preservice areas. As predicted, the responsibilities and expectations of Patient Access staff continue to increase at rapid rates. Meanwhile, many managers struggle to keep up the same pace with training program development.
Many Patient Access professionals feel lost and find it difficult to keep up with daily changes in
payer requirements and financial clearance processes. Employee surveys even show that associates feel the amount of training they receive is insufficient for them to feel confident in completing their daily tasks with accuracy.
As educators, Patient Access managers can help mitigate this problem by providing associates with a solid knowledge base on basic revenue cycle concepts. With a strong foundational understanding of the revenue cycle, associates are better able to make informed decisions when facing new dilemmas by applying information they already know. Instead of trying to memorize every possible detail, associates can feel confident making their own decisions when faced with something slightly unfamiliar.
Over the last several years, Saint Anthony Medical Center started making small tweaks to its employee onboarding program. As the team learned what worked well, it continued to develop the program. Through collaboration across the revenue cycle, it implemented a structured, foundational onboarding program that leaves new hires with confidence, knowledge and interdepartmental relationships that pave the way for a successful career in revenue cycle.
Saint Anthony Medical Center has experienced higher new employee satisfaction scores, improved performance and better patient experience results since implementing its new program. Come to Zuroske’s session, and she will show you how Saint Anthony Medical Center did it. l
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online education for revenue cycle and Patient Access teams across the United States and was an early believer in the power of AccessKeys. It quickly became the exclusive provider of revenue cycle and Patient Access training for NAHAM at the national level. Litmos Healthcare provides quick, engaging online education that align exactly with the AccessKeys that clients choose to measure and improve.
For example, NAHAM AccessKey 1: Point of Service (POS) Collections to Revenue pairs up with course titles such as “Assumptions, Presumptions and Misconceptions in Collections and Three Keys to Effective Collection Communications.” These courses are highly effective in increasing awareness about the importance of the collections process and encouraging registrars, patient financial counselors and the like to understand their role in generating patient revenue.
Improving the patient experience at the front end of the revenue cycle requires constant focus and the correct tools and people for the job. Using the AccessKeys, you already have the good-better-best goals and the calculations to help measure your success. An important part of this process is engaging in discussions with your peers at other facilities and understanding the tactics already employed by successful Patient Access professionals like Carey and Fountain. l
Learn How to Get the Most Value out of the NAHAM AccessKeys®
By Terry Kile, CRCP
Session Title: Success Stories with NAHAM’s AccessKeys®
Presenter: Terry Kile, CRCP, Regional Director, Litmos Healthcare Division
Learning Lab: Series 4 and 5
Date/Time: May 26, 3-4:15 p.m.; May 27, 9:45-11 a.m.
It is one thing to understand NAHAM’s AccessKeys®; it is another to put them into practice. With all of the other priorities in Patient Access, it is difficult to take the time to achieve a greater level of revenue. However, look to Adventist Health’s Park Ridge Hospital and OSF Healthcare’s Saint Anthony Medical Center for shining examples of success. The key reason for their success include the combination of the AccessKeys with management focus and staff education.
By now, NAMAM members should have a basic understanding of the AccessKeys and their importance in the operations and benchmarking of patient care. Paul Shorrosh, CEO of Accureg, is one of the driving forces behind the development of the 23 AccessKeys.
The metrics produced in the implementation of the AccessKeys are the perfect foundation to transform Patient Access from a cost center of the health system to a
revenue generator based on the focus on point-of-service collections and other processes that directly affect the bottom line.
During the session, “Success Stories with NAHAM’s AccessKeys,” Colin Carey, director of Patient Access at Park Ridge Hospital, Hendersonville, North Carolina, and Nicole Fountain, revenue cycle director at Saint Anthony Medical Center, Rockford, Illinois, will share their stories of implementating of specific AccessKeys from managing the day-to-day education and supporting the employees and supervisors to measuring the impact of the program on interactions with patients and their families. Terry Kile, regional director for Litmos Healthcare, will also present information on ease of use of the program and help attendees focus their efforts for the best chance of success.
Litmos Healthcare, formerly BridgeFront, is a leading provider of
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time, no more real estate was going to be approved for Patient Access and the team needed to come up with a plan to continue to provide an exceptional patient experience, but provide that experience from home. This initiative was a completely new and non-traditional concept for the team.
The team had numerous brainstorming sessions to conquer the many questions that the team members were asking. Which services could be provided from home? Who gets to work from home? What must the employee provide? What should the employer provide? What should a home work station require? How would employees be supervised? How do we ensure that patients were being well taken care of ? Each question culminated in another question.
If your Patient Access team has ever considered implementing a work-from-home program, speaker Tracey Shetter, CHAM, CHAA, CPAT, manager, Access Call Centers, WellSpan Health, invites you to attend her session at the NAHAM 42nd Annual Conference. She will share with attendees the steps that WellSpan Health took to get to where it is today, the trials and tribulations it faced, the lessons learned and the positive outcomes that it continues to enjoy. l
What happens when your Patient Access departments begin to experience an accelerated growth spurt, so much so, that you literally run out of office space? That is exactly what happened to our various Patient Access teams within WellSpan Health.
Over the past several years, access operations expanded its scope of responsibility to include a wide variety of services that went far beyond registration. The staff created new departments as well as brought existing departments under
Session Title: The Virtual World: Providing Access Services from Home!
Presenter: Tracey Shetter, CHAM, CHAA, CPAT, Manager, Access Call Centers, WellSpan Health
Learning Lab: Series 1
Date/Time: May 25, 1:15-2:30 p.m.
WellSpan Health Undergoes Major Change to Embrace Virtual Office Environment By Tracey Shetter, CHAM, CHAA, CPAT
the Patient Access umbrella. Two more hospitals joined WellSpan Health’s healthcare system and staff began to integrate some of the services at a corporate level. Not only was the Patient Access team running out of work stations to host all of its new colleagues, it was running out of square footage to even be able to add more work stations for them.
In 2014, leaders within the Patient Access team were challenged to embark on a journey into a new world: The virtual world. At that
Tracey Shetter will share with attendees the steps that
WellSpan Health took to get to where it is today, the trials
and tribulations it faced, the lessons learned and the
positive outcomes that it continues to enjoy.
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Striving for One Call: Achieving Excellence in Pre-Access OperationsBy Michael Sciarabba, CHAM
In an effort to be patient-centric, Patient Access leaders commonly ask themselves these questions to develop the best patient-centered strategies and tactics: “What would the patient want; what would I want if I was the patient; what do I want for my family members when they are patients?” These questions are also commonly asked in performance improvement initiatives in an effort to create patient-friendly solutions.
The one answer I commonly hear from patients is that they desire that only one call occurs prior to service to coordinate their visit. It is very clear that patients want one call, just one, to coordinate all the needed clinical and financial information regarding their care prior to service. In fact, patients want one call and one person coordinating their access. In addition, patients prefer that these processes start at the first point of contact and not wait until the date of service is three to five days in the future.
These desires are common realities all Patient Access leaders know, yet applying the concept of one comprehensive pre-service call is relatively rare. Why is it so rare, and why is perfectly integrating patient communication, scheduling, pre-registration and financial clearance in one call prior to service not the norm?
One Comprehensive Pre-Service Call Is BestComplex hospital systems, reporting structures, budgets and priorities have caused us to lose sight of the clear reality that patients want one call to meet all their access needs prior to service. More commonplace is the separation of the major pre-access components: patient information, scheduling, pre-registration and financial clearance. While these units work together, they function as separate components. These non-integrated structures are error-prone, inefficient and difficult to manage. The process inconsistencies, variability in service and multiple handoffs do not serve the patient experience or the revenue cycle well.
Why do we continue to operate in our environment? It is based on a few commonplace myths that need to be dispelled. These myths prevent Patient Access leaders from owning the pre-access
encounter in an effort to create the ideal, patient-centered, pre-access processes. And, it is the Patient Access leaders who have the needed expertise and capacity and are best suited to spear head these complicated and challenging workflows. Let’s take a moment to dispel five myths and explore their true realities.
Myth 1: Scheduling Is a Clinical FunctionScheduling is not a clinical function, and it can be learned by Patient Access professionals. In fact, scheduling should be coordinated objectively using algorithms and templates to ensure outpatient utilization and productivity are maximized. Scheduling should be performed in a consistent and standard method to reduce the potential for error and
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ensure that expectations are clear. In addition, minimizing handoffs between individuals and departments has consistently shown improvements in patient safety and service. Patient Access professionals are best suited for these roles. Clinical specialists should be involved in clinical intake and assessments, but the majority of general outpatient diagnostic appointment scheduling and provider scheduling is not a clinical function.
Myth 2: Physician and Hospital Appointments Need to Be Coordinated SeparatelyPhysician and hospital appointments should be coordinated together, and many hospitals are doing this now with integrated electronic medical records (EMRs); price estimators; combined statements, etc. Shouldn’t all the patient’s financial questions be addressed at first point of contact, be it in the clinic, physician’s office or hospital? All too often, patients learn of coverage limitations after their physicians’ appointments and after the physicians have accepted them as patients, putting the hospital in a difficult position. The patient doesn’t understand the age-old separation of the physician and hospital processes. Pre-access should bridge this divide and start at the physician’s office. Effective pre-access should be a coordinated approach between physician and hospital entities. It is becoming more commonplace with the expansion of physician-employed hospital networks—a welcome and overdue change.
Myth 3: More Resources Are Needed to Integrate All Components of Pre-accessMore resources are not needed, but we do need the right resources. The right people with the right pay who believe that their work in healthcare
is a special, professional practice is all that is truly needed. Looking for people with concierge-type roles in other industries can also help. As long as people care about their work and leaders support this passion, doing more with less can be accomplished. Organizations all over the country are developing concierge-type models to pre-access and are very successful. Service observing and deploying shared governance and quality enhancement programs can quickly identify deficiencies and should be used to mange this diverse workforce with a diverse set of responsibilities.
Myth 4: One Call Requires too Many Tasks and too Much TimeThis myth is not true and can be proven by measuring key pre-access metrics to ensure efficiency. Some of the best call metrics to focus on include average speeds of answer, average talk time, abandon call rate and no-show rate. Best practice measures for accuracy are insurance verification rate and secure rate.
Productivity should be measured by comparing the cost of labor to volume. Once measured, it is easy to see how task and time can be managed to yield positive results on the patient experience and revenue cycle. These metrics should be widely available and transparent to staff in real-time so that they can adapt to peaks and trends in the daily ebb and flow of work. This will promote a culture of autonomy and accountability.
Myth 5: Physical Space and Budget Limitations Are Barriers to the One Call MethodThe one call concept demands high integration between systems and processes. Showing a technical need that reduces rework and over processing that enables the one call
model should be presented and quantified. Innovative solutions can be designed to ensure that integration exists. By adding up the many labor costs in a muti-call model, it’s easy to see where opportunities exist to reduce cost and improve the process simultaneously. Pre-access work is no longer restricted to the hospital or business office settings. Pre-access work can be done remotely, as long as safeguards on patient privacy are required and maintained. This will save expenses on physical infrastructure. Self-service solutions can be created for patients and organizations to save additional cost and time.
The future of healthcare is changing rapidly, and it is in our hands. Physician and hospital integration, the desire for a shared ADT (platform), mobile technology and remote working options bring us closer to creating the ideal pre-access one call system for patients. This approach yields positive outcomes for the patient experience, the revenue cycle and Patient Access professionals. As Patient Access leaders, we must lead this charge forward, creating a win-win for our patients and our organizations. l
Michael Sciarabba, CHAM, is the vice president of Patient Access for American Health Connection. He has dedicated himself
to Patient Access management and revenue cycle management over the last 20 years and has worked on the front line, quickly progressing into various leadership roles. He is a past president of the Association of Illinois Patient Access Management (aIPAM), as well as an active member of NAHAM, serving on the NAHAM Board of Directors as the chair of the Government Relations/Policy Development Committee.
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After several years of preparation and governmental delays, ICD-10 officially arrived in the United States on Oct. 1, 2015. General industry literature and feedback indicate organizations experienced an overall smooth transition without too much disruption so far.
Does this imply we should cross ICD-10 off our list of items that still require ongoing monitoring, education and future planning? This is unlikely, as there are facets of the ICD-10 transition yet to unfold, as well as updates to the evolving medical code set. Since ICD-9 remained static for many years due to its anticipated retirement and limitations, we need to modify our approach to accommodate a more robust and expandable ICD-10 code set moving forward.
While diagnosis coding to the correct level of specificity is the goal for all patient encounters for 12 months after ICD-10 implementation, Medicare review contractors will not deny physician or other practitioner claims billed under Part B physician fee schedule through either automated medical review or complex medical record review based solely on the specificity of the ICD-10 diagnosis code as long as the physician/practitioner used a valid code from the right family. A grace period for claims in this category is currently in effect, and we will need
to ensure appropriate documentation and ICD-10 code specificity to avoid claim denials once the grace period ends.
Since the ICD-10 code set has been frozen for new updates during the past few years due to implementation delays, minimal changes and enhancements have occurred.
I anticipate numerous updates to the ICD-10 code set effective Oct. 1, 2016 and moving forward. This implies that impacted computerized applications and software should be updated in a timely manner to ensure the most recent ICD-10 codes. Where needed, updated ICD-10 coding books and reference materials
ICD-10: Life in the Post-Transition World By Christina M. Janus, MBA, RHIA, CHAM
Since ICD-9 remained static for many years due to
its anticipated retirement and limitations, we need to
modify our approach to accommodate a more robust and
expandable ICD-10 code set moving forward.
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with ICD-10 code selection for medical providers
�� Customized mandatory education for all impacted professionals, both online and classroom style
�� Internal American Health Information Management Association Certified ICD-10 Trainers to assist with training and leading coding roundtables
�� Pre-go live dual quality reviews for coding and conducting coding
�� End-to-end payer testing with multiple payers, including the claims adjudication process payers covering all patient visit types
�� Clinical documentation reviews with follow-up education for providers
�� Proactive financial projections to identify potential diagnosis related group (DRG) shifting
�� Ensuring professionals have updated and helpful recourses to facilitate learning
�� Monitoring post-go live metrics, including discharged not final billed (DNFB) accounts, accounts receivable days, claim denial rates, coding and other revenue cycle workflow productivity and quality measures, and case mix index as well as conducting a post-go live compliance audit
�� Organization-wide communication regarding project milestones and any changes
Moving Forward In reflecting on the past five years, abundant industry preparation, collaboration and effort took place to ensure a smooth ICD-10 launch. There have been some minor toe-stubbing issues, although the extensive groundwork continues to pay off.
While much has been accomplished, there are reasons why ICD-10 should continue to remain a focus. It is imperative that revenue cycle professionals and clinicians are consistent with their ICD-10 knowledge and skills, as needed for their roles. The CMS grace period ends Oct. 1 for ICD-10 and accurate clinical documentation and coding will have an impact throughout the healthcare industry. Continuing education and system updates will be necessary as the ICD-10 code set evolves and is applied toward industry benchmarks, performance outcomes, studying patient populations, monitoring trends and future planning. Although the day Oct. 1, 2015 has come and gone, ICD-10 will remain a journey for years to come. l
Christina Janus, MBA, RHIA, CHAM, is an experienced revenue cycle professional who has been working in the industry for 25
years in a variety of roles. Since 2009, she has been employed by the MetroHealth System in Cleveland, Ohio, initially as the associate director of Patient Access services, and was appointed to the position of associate director, ICD-10, in 2011 to lead the ICD-10 transition. Janus’ undergraduate degree is from The Ohio State University in HIM, and she holds an MBA from Baldwin-Wallace College. She is actively credentialed as a RHIA through AHIMA and a CHAM through NAHAM and is an active member of HFMA.
should be obtained, and impacted revenue cycle professionals and clinical providers should be educated on any new changes as appropriate for their roles.
MetroHealth’s Advance Preparation Paid Off MetroHealth, an integrated public health system located in Cleveland, Ohio, and throughout the surrounding Cuyahoga County, diligently prepared for the ICD-10 transition for five years. A multidisciplinary ICD-10 steering committee with the CFO and CIO as executive sponsors was established early on to prepare for this large transition. The initiative was driven by a revenue cycle operations project manager, an information services project manager, a physician champion and an array of impacted professionals to cover the multiple facets of ICD-10.
Overall, the ICD-10 transition has been smooth for MetroHealth thus far due to the following reasons:
�� Long-term planning with dedicated project leaders and ICD-10 steering committee
�� Multidisciplinary team involvement with executive sponsorship
�� Extensive computerized system and workflow testing
�� Implementation of technology to mitigate staff productivity and data quality risk, such as computerized coding and diagnosis calculator to assist
It is imperative that revenue cycle professionals and
clinicians are consistent with their ICD-10 knowledge and
skills, as needed for their roles.
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Association News
Get Involved by Joining a NAHAM CommitteeIf you have been wondering how to get involved, joining a NAHAM committee is a great place to start. Whether you know what committee you’re interested in or you’re still not sure, don’t miss out on the committee meetings taking place at the NAHAM Annual Conference and Exposition. The meetings will be held Thursday, May 26 from 4:30-5:50 p.m. CT in New Orleans. Current committees include:
Revised NAHAM Introduction to Patient Access Services Manual Now AvailableThe NAHAM Education Committee recently completed a revision of the NAHAM Introduction to Patient Access Services Manual. This helpful guide reviews a variety of essential topics and serves as a resource during orientation and development for your front end staff. Topics include revenue cycle basics, Patient Access services overview, finance and insurance, agencies and government regulations, customer service and more. Visit the NAHAM website to purchase the complete manual or view the sample document.
�� Certification Commission
�� Membership
�� Policy Development & Government Relations
�� Publications & Communications
�� Education
�� Special Projects
�� Industry Standards Committee
�� Meeting Organizing Committee (an ad-hoc committee appointed annually)
There is no commitment required when you attend these meetings—it’s just a good opportunity for you to investigate your options. If you do find a committee that you’re interested in joining, submit your name and email address at the meeting and get ready to give back to the NAHAM and Patient Access community. For more information about NAHAM’s six committees, take a look at the NAHAM website at naham.org/Committees.
NAHAM Updated Patient Identity Integrity ToolkitNAHAM’s Policy Development and Government Relations Committee
recently made some updates to the Patient Identity Integrity (PII) Toolkit.
If you haven’t heard about the PII Toolkit yet, it is a valuable resource
for Patient Access professionals to access ideas and best practices
around managing and maintaining integrity of patient identity and patient
information. The PII Toolkit includes a patient identity checklist and
question set, which contains recommendations such as asking a patient
to state and spell his or her demographic information and developing
standard scripts to reduce patient identification errors. The toolkit also
highlights the key practices and procedures necessary to ensure integrity
of patient information at all stages of patient flow and experiences as
well as a recommended algorithm for collecting patient information. The
recent update expands upon these features and now offers a vendor
grid to identify NAHAM Business Partners who offer products related
to Patient Identity. For more information, visit the PII Toolkit tab on the
NAHAM website.
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NAHAM has teamed up with LifeMed ID to create a course focused on a top Patient Access concern: obtaining positive patient identity. Validating patient identity is crucial to the continuity of patient care and the reduction of patient record errors and fraud to a hospital or care facility. Accurately identifying patients and linking them to the correct medical record is paramount to proper patient treatment.
This course will explore the following:
�� The importance of patient information and identity validation
�� The benefits of proper patient authentication
�� The types of fraud and abuse that can occur
This course is available for download on the NAHAM website.
Save the Date for Access Week April 3-9 Patient Access Week is just around the corner; don’t miss out on this opportunity to recognize your fellow healthcare access professionals for their continued accomplishments and services in the healthcare access continuum. By supporting and promoting Patient Access Week, you are showing your team that you appreciate their hard work and encourage their efforts as goodwill ambassadors for the entire facility, and you’re demonstrating the important of Patient Access to your entire facility. A recognition program implemented during this special week is an excellent means to enhance guest relations, increase hospital morale and improved communications.
This year, NAHAM has put together a number of materials and tools to help you and your organization celebrate this special week. NAHAM encourages you to share this informationwith members of your staff so everyone can be an active participant in the planning and implementation process. Remember, this information is meant only as a guide for your promotional activities, so feel free to add your own ideas to develop the perfect week for your staff. And don’t forget to share your creative ideas with NAHAM by emailing [email protected] with information, photos and more. For more information, visit the NAHAM website at naham.org/AccessWeek.
NAHAM and LifeMed ID Present New Positive Patient Identity Course
NAHAM Recognizes Its Current Business PartnersNAHAM Business Partners include those individuals who work for businesses that serve the healthcare industry with particular relevance to Patient Access services. NAHAM would like to thank each of its business partners for their membership and encourage members to reach out to them for related business questions.
RelateCareProvider Advantage NW, IncCrossChx, Inc.RecondoBridgefrontExperian Health/Passport
Database Solutions, Inc.eSolutionsSCI SolutionsTrace/The White Stone Group, Inc.LifeMed ID, Inc.Zenig
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Readers will recall NAHAM’s response to the Federal Communications Commission’s Declaratory Ruling and Order on July 10, 2015, which addressed several provisions of the Telephone Consumer Protection Act (TCPA) regulations. And for those who follow NAHAM’s blog, NAHAM News, you will recall the post, “Deconstructing the FCC’s Declaratory Ruling on TCPA Regulations.”
More recently, NAHAM News posted, “Hospital Company Sued Under FCC’s Tighter TCPA Rules.” In that post, NAHAM reported on a class action lawsuit, reportedly one of the first lawsuits since the FCC’s July interpretive ruling. The lawsuit alleges that a hospital used an automated dialer to call a patient’s cellphone in order to collect a debt without the patient’s express consent to do so.
With these developments, I think it is a good idea to revisit NAHAM’s analysis of the FCC’s ruling and what it means for healthcare providers.
Specific to healthcare organizations, the FCC addressed a petition filed by the American Association of Healthcare Administrative Management (AAHAM) regarding the exemption from prior express
consent of “healthcare-related messages.” AAHAM sought clarification on exemptions that are currently found in the TCPA for calls subject to the Health Information Portability and Accountability Act (HIPAA).
The HIPAA exemption in the TCPA regulations currently extends to advertising and marketing calls to cellphone and residential landline phone numbers. Under the exemption, calls that deliver a healthcare message made by or on behalf of a covered entity or its business associates, as defined in HIPAA, do not require the prior express written consent of the party called. A point of confusion was whether non-telemarketing calls (for example, informational or transactional calls) that deliver healthcare messages require patient consent.
The petition asked the FCC to clarify if for calls subject to the HIPAA exemption, an individual’s voluntary provision of his or her cellphone number to a healthcare provider constitutes prior express consent to be called on that number. The FCC had already ruled in a different proceeding that an individual’s provision of his or her cellphone number is effectively an invitation to be contacted at that number, as long as the calls or texts
are limited in scope to the purpose the number was provided in the first place. In its July 10, 2015, findings, the FCC extended that reasoning to calls and texts in the healthcare context and agreed that healthcare providers can rely on the voluntary provision of a cellphone number as constituting prior express consent under the TCPA.
It is important to note that only HIPAA-covered entities and their business associates can make healthcare calls subject to this exemption, and calls must be within the scope of the consent given.
The FCC said, “We clarify, therefore, that provision of a phone number to a healthcare provider constitutes prior express consent for healthcare calls subject to HIPAA by a HIPAA-covered entity and business associates acting on its behalf, as defined by HIPAA, if the covered entities and business associates are making calls within the scope of the consent given and absent instructions to the contrary.”
The petition also asked the FCC to clarify consent with regard to incapacitated patients, addressing situations where a patient is incapacitated and unable to provide a telephone number directly to a healthcare provider, while a
Revisiting NAHAM’s ‘Deconstructing the FCC’s Declaratory Ruling on TCPA Regulations: What It Means for Healthcare Providers’By Frank Moore
Advocacy Update
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third-party intermediary may be able to provide a number.
The FCC said, “We clarify, therefore, that where a party is unable to consent because of medical incapacity, prior express consent to make healthcare calls subject to HIPAA may be obtained from a third party—much as a third party may consent to medical treatment on an incapacitated party’s behalf. A caller may make healthcare calls subject to HIPAA during that period of incapacity, based on the third party’s prior express consent.” Consent by a third party on behalf of an incapacitated individual will end when the individual is no longer incapacitated. In such an instance, the provider must get prior express consent from the party being called.
The FCC added, “A caller seeking to make healthcare calls subject to HIPAA to a patient, who is no longer incapacitated, must obtain the prior express consent of the called party.”
The FCC also clarified that certain non-telemarketing healthcare calls, as long as the called party is not charged, are exempt from the prior express consent requirement.
The FCC confirmed that acceptable calls that fall under this “free-to-end-user” call exemption include the following:
�� Appointment and exam confirmations and reminders,
�� Wellness check-ups,
�� Hospital pre-registration instructions,
�� Pre-operative instructions,
�� Lab results,
�� Post-discharge follow-up intended to prevent readmission,
�� Prescription notifications, and
�� Home healthcare instructions.
It is important to note that the FCC made it clear that healthcare calls related to accounting, billing, debt collection or containing other financial content are not part of this exemption.
The FCC said, “While we recognize the exigency and public interest in calls regarding post-discharge follow-up intended to prevent readmission or prescription notifications, we fail to see the same exigency and public interest in calls regarding account communications, payment notifications or Social Security disability eligibility. While this second group of calls regarding billing and accounts may convey information, we cannot find that they warrant the same treatment as calls for healthcare treatment purposes. Timely delivery of these types of messages is not critical to a called party’s healthcare, and they therefore do not justify setting aside a consumer’s privacy interests in favor of an exemption for them.”
Also, the content of the exempt calls are still subject to HIPPA privacy rules. The FCC clarified “that HIPAA privacy rules shall control the content of the informational message where applicable, such as where the message attempts to relate information of a sensitive or personal nature.” The information provided in these calls and texts “must not be of such a personal nature that it would violate the privacy of the patient if, for example, another person received the message.”
The exempt calls are subject to these FCC-imposed limitations, including:
�� Calls must be free to the end user;
�� Calls must be made by or on behalf of a healthcare provider;
�� Calls can only be made or sent to the cellphone number provided by the patient;
�� Calls or texts must state the name and contact information of the healthcare provider;
�� Calls or texts must be “concise” (one minute or less for voice calls and 160 characters or less for text messages);
�� Healthcare providers may only make one exempt call or send one exempt text per day (per recipient) with a weekly limit of three total calls or texts (per recipient); and
�� Healthcare providers must offer recipients an opportunity to opt out of receiving these types of calls or texts and must honor those opt outs immediately.
The exclusive method for opting out of text messages is for the recipient to reply with the word “STOP.” Recipients must be given this instruction.
Additional Information
�� The FCC’s Declaratory Ruling and Order may be found at its webpage using this address: https://www.fcc.gov/document/tcpa-omnibus-declaratory-ruling-and-order.
�� A “NAHAM TCPA Checklist” as well as this briefing, NAHAM’s “Deconstructing the FCC’s Declaratory Ruling on TCPA Regulations: What it Means for Healthcare Providers,” is available at www.naham.org. l
Frank Moore is NAHAM’s Government Relations Senior Director, based in Washington, D.C.
