10/29/2014
CLIENT'S WHO USE THEIR INSURANCE THROUGH THE AFFORDABLE CARE ACT- may have claims paid that will ultimately be recouped by the insurance company. We have seen this in one practice that we serve here at CMH Billing. The claims were filed, processed and paid to the provider in a timely manner.
However, three months later the insurance company sent a letter asking for the claims payments amounts to be returned. The client had stopped coming to therapy and the counselor did not have a credit card on file to charge the amounts she was returning to Cigna.
The insurance company will keep payments meant for other client's until they have recouped the money for the patient who did not make up their premiums. We are sending the client statements but have little hope of receiving payment. Note: the client would have known when she was being seen that she was not making her premium payments but did not inform the office.
Since the insurance company has a right to recoup the money from the provider when premiums are not paid, what is a practice to do? The Affordable Care Act is slanted very strongly in the patient's favor in this instance. There are bills before congress to try to change this and make the law protect providers. We'll see if they pass one.
I suggest knowing which patients' policies are purchased using Advance Premium Tax Credits. This can be accomplished by calling for an eligibility check before each of the patient's appointments and asking customer service specifically if the client is in a 'grace period.'
Additionally you can put this statement on the new client paperwork and require a signature.
- I (the patient) also understand and acknowledge that I am personally responsible to pay (the name of the practice) in full for services that my health insurer will not cover due to non-payment of my health insurance premiums.
I have attached a document form the AMA which outlines a collection policy for grace period patients.
Affordable Care Act "grace period"
Under the Affordable Care Act (ACA), if a patient who receives an advance premium tax credit does not pay his or her health insurance premiums in full, he or she enters a 90-day "grace period." During the first month of the grace period, the patient continues to have health insurance coverage, and the patient's health insurer will pay claims for health care services provided to the patient during that time. However, if the patient enters the second or third month of the grace period, the health insurer may pend claims for services provided to the patient during that time. If the patient pays his or her premiums in full before the end of the grace period, the patient retains health insurance coverage for the second and third months of the grace period, and the insurer will pay the pended claims. But if the patient does not pay his or her health insurance premiums in full before the end of the grace period, the health insurer will not extend coverage for the second or third months of the grace period and will deny claims for services provided during that time. In this case, a patient is then responsible for paying the entire bill for services rendered during the second and third months.
Health insurers are required to notify physicians of patients' grace period status. Still, a number of questions concerning the specifics of notification, as well as other issues of concern to physicians, have yet to be addressed. It is, therefore, important that you find out how your patients' contracted health insurance issuers will provide notice and handle other grace period issues. It is also vital that your practice proactively take steps to minimize any potential non-payments from health insurers that are due to cancellation of coverage at the end of the grace period.
(This advice does not create an attorney-client relationship between CMH Billing and the reader. The reader should receive legal advice from retained legal counsel concerning any issues raised in this email.)