New York University School of Medicine Faculty Group Practice Billing and Collection Policies

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1 New York University School of Medicine Faculty Group Practice Billing and Collection Policies General Policy Statement New York University School of Medicine Faculty Group Practice (NYUSM- FGP) oversees vendors and affiliated billing and collection services by physicians and other health care providers employed by the School of Medicine. To ensure a consistent and compliant approach to billing and collection activities, the NYUSM-FGP will make every effort to oversee that practices: Comply with governmental rules and regulations; Comply with New York University rules and regulations; Obtain timely payment from patients and third-party payors; Attain focused revenue cycle (operational) guidelines; Prepare monthly reports for NYSM-FGP; Conform with recognized principles of internal control; and, Create the highest standard of revenue cycle practices which satisfy, and in some circumstances, exceed legal requirements. In accordance with our stated philosophy, the following policies will serve as guidelines for charge entry, billing and collection of all accounts receivable. Revenue Cycle Policy Statement Medical Coding (ICD-9-CM and CPT) and Documentation Diagnosis (ICD-9) and procedure (CPT) codes will be assigned to the most appropriate degree of specificity based upon signs, symptoms, and/or conditions as indicated in writing in the source document. The codes will be encompassed by the official definition as determined by the American Medical Association, Medicare, the World Health Organization and/or relevant specialty society. The source document must be completed and authorized by the physician performing the billable service. Professional services, diagnosis and supplies will only be coded by the physician providing the service or by qualified, specially trained

2 personnel. Any change in the charge data requires written authorization from the physician and will be attached to the source documentation. Proper source documentation will be utilized for CPT coding purposes. Charge posting All charges will be posted at the practice fee schedule rate. The NYUSM-FGP will work with each practice to establish the fee schedule. All charge information will be posted to the computer billing system within one business day from the time the charge is received at the billing office. When medical coding is performed off-site, charges will be posted within one business day of receipt of completed medical coding information. Incomplete charge information received will be researched the same day and resolved within a week. Charges with incomplete/missing demographic information will be posted to a control account and researched within one week after receipt. Payment Depositing All payments will be directed to a lock box maintained by and in the name of New York University. Payments received at the practice (outside of the lock box) will be deposited within 1 business day of the receipt of payment. Payment, Denial, Payment Pending, and Recoupment Posting Payment posting, denial, payment pending (i.e., explanation of benefits) and recoupment posting will be completed within one business day of receipt of the payment/explanation of benefits from the lock box or mail. External collection agencies will be notified of payments received at NYUSM-FGP for accounts the agency is working. Payments will only be posted for practice accounts. Contractual Allowances Contractual allowances will be posted by payment posting staff (and/or when identified by other department staff) the day the payment is received from the lock box or mail (date of deposit). Physicians requesting professional courtesy adjustments will provide supporting documentation to be placed in the chart. Supporting documentation includes indication by the physician on a charge ticket, a note from the physician or practice manager, or a record of a phone conversation with the physician. The routine waiver of co-payments and deductibles is not permitted. If a copayment is waived on a case by case basis, appropriate disclosure to the insurance payor will be made.

3 Third Party Billing All hard copy claims are sent to the carrier the same day the claim form is generated. Electronic claims are submitted to the carrier in the preferred media (tape, diskette, electronic data transfer) within one business day of when the claim qualifies for billing. Secondary insurance billing is performed the one business day after the primary payment is posted to the account. All billing edit reports (internal and carrier) will be worked and processed within one business day of receipt. Electronic claims are logged when submitted to the carrier, and then are reconciled with the carrier to ensure all claims sent, are received by the carrier. Third Party and Self Pay Account Follow-up Patient accounts with pending insurance payments will be followed up with the payers no later than five (5) business days from the expected payment date. Correspondence from third parties and self-pay patients will be processed within two business days from receipt. An appropriate note will be posted to the billing system. Accounts with insurance and/or patient balances that can not be collected will be written off after 150 days. Self-pay accounts will be billed for a maximum period of 150 days prior to collection agency transfer. Exceptions must be made in writing to the NYUSM FGP office and approved by the Chief Operating Officer. Patient payment plans may be granted in the event full payment is not provided. Self-pay accounts with balances representing the top ten per cent (10%) of the accounts receivable will receive follow-up no later than 45 days from charge entry. Mail returned because of a bad address will be researched for a correct address within one week of receipt. Bankruptcy notifications will be honored and self-pay account balances will be written off to the bankruptcy allowance code. Attempts will be made to file probate with the county probate court if there is an estate and the account is valued in excess of the Small Balance threshold. All collection activities will be conducted in accordance with the Fair Debt Collections Practices Act and the Fair Credit Act. Collection agencies will be notified of payments received at NYUSM-FGP for accounts the agency is working. Fiscal Controls Payment processing, deposit processing, and refund processing will all occur with proper internal controls in place to protect the practices from fraudulent activities.

4 Credit Balances Refunds Credit balances will be reviewed and monitored on an ongoing basis. All credit balance amounts will be researched to verify that the credit is owed to the payer or patients. Refunds will be granted in the following circumstances: when two insurance companies pay for the same service and a credit balance results, the practice will research and refund to the secondary payer. Coordination of benefit rules will be applied by the practices; when the patient/insurance company requests an appropriate refund; when the patient and third party payer pay on an account and a credit balance results; when in the case of Medicare, the amount collected exceeds the allowed amount or limiting charge; when the amount received from Medicare remains unidentified and cannot be posted to an account; when appropriate late credits and/or adjustments are applied to an account and a credit balance results; and, when the patient or payer pays twice. Credit balances will be maintained on the accounts receivable for no greater than 90 days prior to account resolution. No credit balance will be adjusted unless the account meets the small balance criteria, refund criteria, returning of unidentified payments, or if collection agency payments are recorded. Credit balances will be researched within one business day, and resolved within 90 days of the appearance of the balance. Credit balances will be reviewed by the NYUSM-FGP Practice Management Specialists to ensure quality assurance protocols are met. All government credit balances (Medicare, Medicaid, Champus, state or local government) are to be researched daily and processed within five business days. All governmental overpayments will be researched and processed within two business days of payment posting. Two way communication (i.e., certified mail) credit balance/refund documentation will be maintained for Medicare. Notification to Medicare will occur prior to any carrier recoupments. All

5 governmental recoupments will be reconciled to individual patient accounts within one business day of the notification of the recoupment. Refund requests will be researched and if appropriate, processed within one business day. Payments received and deposited for the wrong provider will be transferred to the appropriate practice or refunded to the payer. NYUSM-FGP will process all refund transactions and track misappropriated payments. NYUSM-FGP will have check signing authority. The refund account reconciliation will be performed by NYUSM-FGP. Unidentified Payments Unidentified payments will be researched within one day and resolved within 90 days of payment posting. If the unidentified payment remains unresolved at the end of 90 days, the practice will produce a report of the unidentified payments, and will be instructed to forward the information to the NYUSM-FGP to seek advice from legal counsel regarding compliance with NYS unclaimed property fund reporting requirements. Unidentified payments from Medicare will be returned to Medicare. Small Balance Write-offs Small balance co-payments and deductibles less than twenty five ($25.00) dollars, but greater than five ($5.00) dollars will be billed one time to the patient. Debit balances from all payers of five ($5.00) dollars or less will be written off the system after one bill is sent. Credit balances on government program accounts (government payer, beneficiary and secondary carriers) will be refunded, regardless of the amount. Credit balances for all other payers may be written off the system if the account balance is five ($5.00) dollars or less. Collection Agency Account transfers to collection agency are transferred at 150 days from the date the initial payment/denial is received. Accounts are also transferred immediately to collection agency when a patient refuses to make payment. Collection agencies are notified of payments for collection agency accounts received at the practices. Accounts adjusted off the practices accounts receivable balance are then transferred to a collection agency. State/Federal Billing and Collection Practices NYUSM-FGP operates within the guidelines of all federal and NYS laws and regulations relating to billing practices, including applicable Medicare, Medicaid, Champus, and NYS insurance laws, and will abide by the terms of contracts with all third parties with whom we contract for business.

6 Record Retention Records and documentation will be stored in accordance with established guidelines. Confidentiality All information regarding a patient s financial, clinical or payment status is confidential. Patient information will not be provided to any individuals or groups other than those involved with that patient s treatment, billing or payment without the patient s written consent obtained by the physician practice, except where such disclosure without the patients consent is required or permitted by law. An attorney other than the attorney representing the patient, must provide a subpoena or court order in order to receive information related to a patient or procedure. Information released to the above stated parties will be limited to the specific account(s) noted.