With the healthcare industry preparing for provisions of the No Surprises Act to take effect on Jan. 1, 2022, the year-end crunch is getting crunchier. The law aims to increase transparency and decrease unexpected bills for patients.
Chief compliance officers can help facilitate a smooth rollout for their organizations by focusing on serving as a strong business partner.
Prioritize training staff on the No Suprises Act
“Training staff on the complexities of the provisions and role-based training” are the biggest challenges facing hospital CCOs in preparing their organization for compliance, says Shawn DeGroot, president of Compliance Vitals.
Leaders have wide-ranging training priorities. They have to make sure the required disclosures are integrated into front- and back-end processes and educate staff on how to communicate changes to patients. The front-end focus includes registration and scheduling, and on the back end, billing, and dispute resolution processes.
Guiding an organization through change first requires hospital leaders’ buy-in. Establish a steering committee to develop your organization’s policy and appoint key players from across the organization. Whether the committee is led by a CCO – or in a larger organization, a project manager – it should include leaders such as the CFO and COO, as well as the heads of registration, billing, and scheduling.
A steering committee can collaborate on addressing the pricklier points of complying with the No Surprises Act, including
- Communicating with patients and other impacted departments
- Maintaining a list of good faith estimated charges
- Keeping a list of which insurance plans the provider is participating with
- Developing a dispute resolution process
As part of the steering committee, demonstrate your leadership as an effective business partner by outlining the challenges facing the organization and proposing solutions, allowing committee members to provide input but not expecting them to come up with all the answers. Also, keep in mind that starting with an explanation of the complexities in basic terms is helpful; business leaders may not know the regulations as well as CCOs.
A key first directive for the committee is appointing a leader to draft the compliance policy and circulate it among subject matter experts, who review their pieces of the puzzle to help finalize the policy.
The CFO, for example, can advise on billing changes and how they will look from a payor standpoint. The COO can manage contract negotiations, advise on handling issues such as a physician group that isn’t participating with an insurance provider, and design a dispute resolution process based on federal requirements around arbitration.
Develop education and communication tools for No Suprises Act compliance
Education and communications are crucial for a smooth rollout. The steering committee should choose a cadence for updates, whether weekly or monthly, to help compliance and training efforts remain top of mind.
The committee should oversee development of education and development tools – including presentations, scripts, and FAQs – to ensure that everyone understands what the law is, what the new requirements are and how your organization will comply.
It may be helpful to create two versions of a presentation – a high-level overview for leaders, and another for front-line staff, focused on the nuts and bolts of the upcoming changes to their daily workflows. Both versions should explain the background on the law and its requirements. This includes a walk-through of the required disclosures and the “why” behind them. It also includes copies of required disclosures so everyone can see what they look like.
The FAQs and scripts for front-line staff should address common scenarios they are likely to encounter, and the steering committee should designate who will conduct staff training. A big change for front-line staff is being responsible to walk through a notice with patients. Additionally, front-end staff will need a process for addressing patient questions. Topics to cover include:
- How will the good faith estimate of expected charges be provided to patients, and – if patients ask – how were the charges determined?
- How are patients notified when the provider is out-of-network?
- Where is this information available on the organization’s website?
- How will disputes be handled related to any bills received that substantially exceed the good faith estimates?
“Partner with the affected departments to train staff and implement a process to address the provisions in the legislation,” DeGroot recommends.
Once your organization’s policy is completed, and education and training are under way, the last steps include finalizing the required disclosure form and loading it into the computer system. Finally, identify which staff are responsible for delivering the notice, and ensure the staff know where the disclosure form is located and how to access it.
You can use the Model Disclosure Notice published by the Centers for Medicare & Medicaid Services (CMS). For model procedures, policies, and expert tools specific to provisions of the No Surprises Act already in place, YouCompli offers practical tools to simplify your compliance with this Act.
A law as complex as the No Surprises Act requires extensive training, education and communications to prepare an organization for demonstrating compliance. As a business partner, you can set the tone by supporting efforts to get leaders’ buy-in and train staff. Fostering an approach of continual communications keeps everyone informed on the issues facing the organization – and the plans to resolve them – and on track for a smooth implementation.
Jerry Shafran is the founder of YouCompli.
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