7 Top-Line Responses to Healthcare s At-Risk Revenue:

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1 7 Top-Line Responses to Healthcare s At-Risk Revenue: Compliance Concerns for Healthcare Business Offices, EBOs, Providers, Hospitals and Their Partners Presented by Ontario Systems, LLC Hosted by insidearm

2 Meet the Presenters Rozanne Andersen Vice President and Chief Compliance Officer Ontario Systems, LLC Tom Gavinski Vice President Revenue Cycle ARS National Terry Armstrong President State Collection Service, Inc. Connie Perez President Adreima Albert Cadena President and Chief Executive Officer USCB America Steve Scibetta Senior Director, Channel Sales Ontario Systems, LLC 2

3 Disclaimer Disclaimer: Ontario Systems is a technology company and provides this presentation solely for general informational and marketing purposes. You should not rely on the content of this material for any other purpose or as specific guidance for your company. Ontario Systems advice, services, tools and products described herein do not guarantee compliance with any law or industry standard. You are ultimately responsible for your own company s actions and compliance efforts and should consult with your own legal and business advisors to obtain specific advice on your company s compliance, legal and other business needs. Despite Ontario Systems efforts to provide current and up-to-date information, you need to recognize that the information contained herein may become outdated quickly and may contain errors and/or other inaccuracies. The presenters and Ontario Systems assume no liability for typographical or other errors contained in the presentation and materials or for changes in the law affecting anything discussed herein. 3

Ontario Systems advice, services, tools and products described herein do not guarantee compliance with any law or industry standard.

4 Today s Topics 1. Wake up call for healthcare accounting offices, EBOs, providers, hospitals, and their partners 2. Medical debt complaints and the CFPB s complaint portal 3. The Patient Financial Experience is the Consumer Experience 4. Summary of the new National Consumer Assistance Plan regarding the reporting of medical debt to credit reporting agencies 5. The impact of the 501 (r) regulation on the collection process 6. The need to revamp your service provider oversight program 7. Attributes of a top notch healthcare collections partner and its impact on the patient experience 8. Best practices that drive a great healthcare provider/receivables partner relationship 4

Summary of the new National Consumer Assistance Plan regarding the reporting of medical debt to credit reporting agencies 5.

5 You Have a Target on Your Back U.S. Treasury s recent publication of the final 501 ( r) rule Credit Reporting Agencies collaboration with the State of New York Status of proposed legislation to remove medical debt from a consumer s credit report Consumer driven litigation Unfair, Deceptive, or Abusive Acts and Practices [UDAAP] Telephone Consumer Protection Act Vicarious liability claims/negligent retention and supervision of service providers Consumer complaints The Consumer Financial Protection Bureau s recent actions 5

of proposed legislation to remove medical debt from a consumer s credit report Consumer driven litigation Unfair, Deceptive, or

6 Recent Actions by the CFPB Medical debt collections field hearing December 11, Mandatory reporting of consumer dispute data Consideration of proposed rules regarding their authority to regulate, supervise and examine healthcare providers and medical debt collection agencies Consumer Groups Weigh In Publication of guidance bulletins re: Credit reporting/medical debt credit reporting Investigation of consumer disputes Service provider management and oversight Go to CFPB.gov 6

and medical debt collection agencies Consumer Groups Weigh In Publication of guidance bulletins re: Credit

7 Medical Debt Complaints and the CFPB s Complaint Portal Number of Complaints Medical debt is on the CFPB s radar Who must register? What to do when you receive a CFPB generated complaint? Jan Feb Total Medical Debt Collection Complaints March 351 April 323 May 373 June 426 July 455 Aug Month/Year 374 Sept 430 Oct 389 Nov 404 Dec 510 Jan Feb March 2015 Medical Debt Complaints Month Total % of All Industry Complaints Jan % Feb % March % April % May % June % July % Aug % Sept % Oct % Nov % Dec % Jan % Feb % March % 7

600 500 400 300 200 100 0 313 Jan 330 323 Feb Total Medical Debt Collection Complaints March 351 April 323 May 373 June 426 July 455 Aug Month/Year 374 Sept 430 Oct 389 Nov 404 Dec

8 Breaking News FCC Speaks Federal Communications Commission announces Open Meeting June 18 TCPA rulemaking to be addressed through declaratory rulings and orders Ruling on definition of need for an ATDS to have the present capacity to generate random and sequential numbers anticipated Hundreds of petitions pending 8

and orders Ruling on definition of need for an ATDS to have the present

9 The Patient Financial Experience is the Consumer Experience First- and third-party collection partners an extension of your organization The patient experience and the receivables management process Stewardship continues through the collection cycle Patient KPIs 9

organization The patient experience and the receivables

10 The New National Consumer Assistance Plan Collaboration between Experian, Equifax, Transunion and the New York State Attorney General Announced March 2015, effective dates vary per requirement Impacts all U.S. consumers Key elements Google National Consumer Assistance Plan 10

General Announced March 2015, effective dates vary per requirement

11 501(r) Reg s Impact on the Collection Process Who must comply and why? When does the requirement take effect? What is required? FAP Written and oral communications Calculation of the application period 120 days x 2 Definition of Extraordinary Collection Activity and the 30 day notice letter How can first- and third-party agency partners help? 11

FAP Written and oral communications Calculation of the application period 120 days x 2

12 Revamp Your Service Provider Oversight Program - Today Definition of service provider The buck stops with the healthcare provider Lessons learned from HIPAA and the BA agreement Due diligence during selection process Due diligence throughout the relationship With the right to hire comes the duty to fire 12

HIPAA and the BA agreement Due diligence during selection process Due

13 Attributes of a Top-Notch Healthcare Collections Partner Culture Operations Compliance management system Description of a robust CMS Telephone Consumer Protection Act/Consent Credentials and certifications Market position 13

Description of a robust CMS Telephone Consumer

14 Best Practices That Drive a Great Healthcare Provider/Receivables Partner Relationship On boarding Due diligence Compliance Reporting Accounting Communication 14

15 Question and Answer Rozanne Andersen Vice President and Chief Compliance Officer Ontario Systems, LLC Tom Gavinski Vice President Revenue Cycle ARS National Terry Armstrong President State Collection Service, Inc x330 Connie Perez President Adreima Albert Cadena President and Chief Executive Officer USCB America Steve Scibetta Senior Director, Channel Sales Ontario Systems, LLC

3981 Terry Armstrong President State Collection Service, Inc terrya@stcol.com 608.661.3000 x330 Connie Perez President Adreima connie.perez@adreima.com 602.

16 Thank You for Attending Please Follow Us Visit the Ontario Systems blog at hub.ontariosystems.com 16

ANALYZING THE FCC S OPEN JUNE 18 MEETING:

ANALYZING THE FCC S OPEN JUNE 18 MEETING: The Instant TCPA Clarification Reaction from Rozanne Andersen and Rip Harris Disclaimer Disclaimer: Ontario Systems is a technology company and provides this presentation