HFMA, ACA Seek Your Input on Universal Medical Collection Guidelines

(Updated Sept. 3)

Now is the time to comment on proposed medical collection guidelines that, when finalized, sponsors hope will find wide acceptance by the healthcare industry and its partners.

The Healthcare Financial Management Association (HFMA), ACA International, and other stakeholder organizations representing credit bureaus, consumer protection agencies, and more, earlier this month distributed to their respective members “The Medical Debt Resolution Overview,” which also includes a step-by-step workflow with recommendations on how providers and their collection-related partners should manage the debt collection process.

The proposed guidelines and flowchart were released to members of ACA International, HFMA, and other stakeholders seeking their feedback. HFMA has asked it’s members to respond by Friday, Aug. 30 Sept. 6.

Among the task force’s recommendations:

• Allow 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.
• Standardize “collection process clock.” The proposed guidelines recommend that the collection process clock starts at first statement date from provider’s system.
• Collection partners 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.”
• Providers and partners must regularly reconcile accounts. “Regular reconciliations should occur between provider system and business affiliate system.”
• Track and report patient complaints. “All business affiliates involved in account resolution activities are required to report patient complaints.”

Once all the stakeholder organizations have commented, the task force will reconcile and consolidate the guidelines into one, overarching document, which will then be sent to the stakeholder boards—HFMA, ACA International, and others—for consideration and if approved released to members and the public.

Read the complete story at our sister site, insideARM.com.