November 12, 2019
5 Steps: Preparing for questions about financial assistance policies
The stories are everywhere: Health systems using collection agencies and the courts to receive payment for care provided to patients.
- Demonstrators protest Johns Hopkins Hospital suing poor patients
- $439 hospital bill leads to two-year legal battle with Medical Recovery Services
- University of Kentucky bill collection feud heads to Kentucky Supreme Court
- As Patients Struggle With Bills, Hospital Sues Thousands
- ‘UVA Has Ruined Us’: Health System Sues Thousands Of Patients, Seizing Paychecks And Claiming Homes
The exposés are driven by heart-wrenching narratives about patients’ desperate financial straits and what can appear to be a callous, merciless approach by health systems to extract money from them.
In almost every case, the very mission of the health system collecting from patients is called into question.
These populist stories are part of a larger discussion we see emerging in the media and elsewhere. Hospitals and health systems are now being lumped in with pharmaceutical companies and insurance corporations as drivers of increased healthcare costs. This discussion questions the very role and value of hospitals, the “profits” they make, and the purpose they serve. Do they – you? – make “too much?” Are they fulfilling their purpose?
This is what it looks like when the great erosion of trust that has touched most every institution of our society reaches America’s health systems.
The “surprise” in the stories is grounded in assumptions of what a health system should be and how it should act, the human cost of the brokenness of healthcare financing, and the sometimes uncomfortable but very real struggle of hospitals to get paid for the services they provide.
At the heart of things, it’s all about broken trust.
These stories – and scrutiny of health systems’ collection practices – are not going away any time soon. They will continue and accelerate. As we move into the 2020 political season, the likelihood that you could soon find the collection practices of your organization dragged into the media sunshine, for better or worse, is increasing.
Are you prepared? Possibly not. You’re working on multiple fronts – helping a complex health system succeed and serving patients as well as you can, including those having trouble with bills. But getting ready is worthy of your time. It’ll take some detective work. A hospital’s collection activities and financial assistance policies span multiple departments and may include outside agents – even those, like collections agencies, your organization no longer uses or has a relationship with. In addition, the information requested is often complex, so it is important to understand that compiling it may take some time.
Take a close look. Even those of you at the most well-intentioned and mission-driven organizations are likely to find things you didn’t know or expect to see.
It will be uncomfortable. Regardless, you should be prepared to explain it and either defend or change it.
Where to begin
Here are five steps you can take today to ensure you understand how your financial assistance and collections could be perceived by others. Throughout this process, be sure to keep your board informed about the steps you’re taking and about the state of the national conversation happening around financial assistance policies. Your board is an ally and an asset, but only if they’re kept up to date and know where to direct questions if asked by the public or media.
1. Ask: Scrutinize your financial assistance and collections policies
An analysis of your existing policies and procedures is needed to determine how the practices could be viewed by others. Here are some questions you should answer before you are asked:
- Does your organization sue patients for past-due bills?
- If so, at what stage does your organization initiate legal action?
- Does your organization add interest to past due bills?
- Is interest added to past due bills through legal action?
- Does your organization sue employees with past-due debt?
- Does your organization sell debt to collection agencies. If so, do they sue for full charges?
- What practices does your debt collection agency use? Are these practices aligned with your mission?
- Are your policies and procedures applied consistently?
- Is your financial assistance policy understandable (by patients, not just legal counsel)?
- Is your financial assistance policy posted where required?
- Is your frontline staff prepared to answer questions AND proactively offer information to patients in need of assistance?
- What are the financial implications of changing your levels of charity care, or your policy on lawsuits, garnishments and liens?
- Are you prepared to answer questions about your policies if they are scrutinized?
2. Reflect: Connect your practice to your mission
After you’ve answered those questions, take a look in the mirror and ask:
- Regardless of legality, are the answers to the above questions aligned with your organization’s mission?
- Are the practices you have in place worth the reputational damage that could occur if they are scrutinized by others?
Another way to ask the question:
- Would your organization be proud to see its collections practices and financial assistance policy featured on the front page of your local newspaper?
- Is your board aware and supportive of your policies and procedures?
3. Listen: Employees and patients can help shape your policies
Your employees know your policies and the consequences – intended or unintended – better than anyone. A review of your financial assistance and collections policies should include an open conversation with your employees to learn how policies are working today and what, if anything, could be changed. You might be surprised what you learn.
And we can’t forget patients. Patients who have accessed your organization’s collections and financial assistance can share firsthand experiences about how those policies affected them. Taking the time to chart the patient experience will provide valuable insights and ensure your policies stand up to scrutiny and are reflective of your organization’s mission.
It’s also worth listening to other stakeholders. Your board is a valuable resource with deep ties to the community. Local, state and even federal legislators understand the healthcare policy landscape and your place within it. They are watching these stories, too, and proactively engaging them may help you navigate issues if they arise.
4. Act: Update policy appropriately, if necessary
Self-assessment is hard. Making necessary changes? Even harder.
Once you’ve asked yourself tough questions and listened to employees and patients, you will be able to make an informed decision about how your policies or practices should evolve, if they should at all. If not, be prepared to defend them. Assume you are on the receiving end of the stories linked above.
It’s critically important to follow up with relevant stakeholders once decisions are made and before you go public with them. Go back to your employees and any patients involved in focus groups to let them know how their input informed your work. Giving them a heads up will build trust, even if you weren’t able to do everything they suggested.
5. Review: Commit to regularly review your policy
This one is pretty simple. Once you’ve made changes to your hospital’s financial assistance policy, set up a regular policy review. Occasional check-ins will serve two functions: 1) to ensure your organization is executing on the policies appropriately and 2) provide opportunities to make additional updates if circumstances dictate.
Taking the time to think through these five steps today will preserve your reputation tomorrow. Isn’t your reputation worth it?
Of course, these five steps assume that your policies are not already being questioned. What would you do if an advocacy group or journalist was making accusations about your policies today?
Stay tuned for the next edition of High Stakes…