PRIMARY CARE OPERATIONAL GUIDELINES



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1 of 6 INTENT: To ensure consistency of application and processes related to the submission, tracking, reconciliation and distribution of revenues generated from Physician, Physician Assistant, and Nurse Practitioner across all WRHA Primary Care Operated Clinics including Quick Care Clinics. DEFINITIONS: Third Party Billing - refers to activities that are not insured by Manitoba Health but may be billed to and paid for by other third party insurers. Examples include Manitoba Public Insurance (MPI), Workers Compensation Board (WCB), Blue Cross, Great West Life, etc. DISTRIBUTION OF THIRD PARTY BILLING FUNDS: All independently contracted physicians working in WRHA Direct Operation Primary Care Clinics receive eighty percent (80%) of all Third Party revenue. NOTE: For taxation purposes it is not appropriate for the Physician to keep 100% and then write a personal cheque to the WRHA for 20% of the amount billed and paid. The 80/20 split does not apply to WRHA Physician Assistants or Nurse Practitioners; 100% of revenues generated by WRHA Physician Assistants and Nurse Practitioners are retained by the WRHA. OPERATING GUIDELINE: Upon receiving an electronic request for release of health information from a Third Party, the Primary Care Assistant (PCA) will transfer the documents into the Physician/Physician Assistant/Nurse Practitioner in-box within the Electronic Medical Record (EMR) for completion and processing. Subject line for the task should read PHIA REQUEST DUE DATE DD/MMM/YYYY. This format will serve as a reminder to all that a time sensitive Third Party request has been received and requires attention. In the event of paper copy requests received, these would be scanned into the EMR before following the same process noted above. Physician/Physician Assistant/Nurse Practitioner is to identify the occurrence of a Third Party billing opportunity on the Clinic Day Sheet. Physician/Physician Assistant/Nurse Practitioner completes work related to the Third Party Billing and may access WRHA transcription services as needed. Clinic staff is not expected to transcribe dictations.

2 of 6 The designated PCA will generate an invoice in accordance with either of the following fee schedules: 1) WRHA Acute, Long Term & Community Care Sites Fee Schedule for Patient Information (Appendix D) This fee schedule is used when: a. There is no Physician involvement with release of information; or b. Physician Assistant, Nurse Practitioner, Midwife, or other Provider provides release of information 2) Billing for Uninsured Services Guide (located in EMR-Billing) This fee schedule is used when: a. There is Physician involvement with release of information Be sure that the invoice indicates that funds are PAYABLE TO THE WRHA and should be mailed to the Primary Care site that originated the Third Party claim. Information is recorded into the monthly Third Party Tracking Spreadsheet (Appendix A). It is recommended that this tracking spreadsheet be maintained on a daily basis to improve accuracy and to avoid backlog. The billing information should be recorded on the appropriate spreadsheet, Claims Received or Claims Outstanding, depending on the status of the claim at month end. New claims should be entered onto the Claims Outstanding spreadsheet, then cut & paste (or transcribe information) onto the Claims Received spreadsheet (see next bullet below) once payment has been received. A 2-page monthly tracking report with invoice summary is sent to WRHA Finance within two (2) business days following month end so that they can record into Accounts Payable. Finance will generate payments to Physicians based on Claims Received for any given month. For example, if a claim that originated in January is received by the WRHA in May, the Physician will be paid their portion of that claim during the May Medical Remuneration payments. In addition to the Monthly Report, each site should send the related cheques for deposit. Ensure that the claim number and the month it was invoiced is written on the cheque (or on copies of cheques) so it can be easily identified on the Monthly Report. Finance does not require copies of the documentation related to the claim, but individual sites should retain this documentation for reference. All Third Party recoveries are to be received by the Primary Care Site in which the billable service was provided. If the funds are sent to WRHA Finance in error, then Finance will fax a copy of the cheque and the related documentation to the appropriate Primary Care Site immediately. Finance will retain the actual cheque and reconcile it with the other submissions from that Primary Care Site at month end.

3 of 6 If the Physician/Physician Assistant/Nurse Practitioner receives the recovery directly, they must sign the cheque over to the WRHA in its entirety and forward all original payment and documentation (e.g. receipt) to the Primary Care Site immediately. The Physician/Physician Assistant/Nurse Practitioner may choose to keep copies of paperwork for his or her own files. Upon receipt of the Primary Care Site monthly report and cheques, Finance will deposit the cheques and update Accounts Payable accordingly. Finance will pay the Physician 80% of the recoveries based on the monthly report for claims received. The 20% belonging to the WRHA will be deposited into a central account and tracked by site. 100% of Physician Assistant and Nurse Practitioner billings will be deposited to the WRHA and tracked by site. The Account Code at the top of the Monthly Report should be filled out with the Site Code and Central Cost Centre Code: Access Downtown 10200068 BridgeCare Clinic 10200069 601 Aikins 10200070 1001 Corydon 10200071 Access Transcona 10200072 Access River East 10200073 McGregor Quick Care Clinic 10200375 St Mary s Quick Care Clinic 10200379 Dakota Quick Care Clinic - 10200426 Access Winnipeg West 10200377 Payments to Physicians will be bundled with all other payments owing to Physicians through Medical Remuneration following the bi-weekly payment schedule. Payments for Third Party billing are only processed ONCE each month, following month end processing. As a result, Physicians can expect their Third Party payments on the Medical Remuneration payment date that occurs in or around the middle of the following month. For example, payments for claims received during the month of May will be paid in and around the middle of June. Finance will provide the clinics with information related to the 80/20 split for the purposes of the site records. Since Third Party payments are combined with all other Medical Remuneration payments in the same deposit, the Sites may use this information at their

4 of 6 discretion to inform Physicians regarding the portion of the payments that are related to Third Party activity. Sites are responsible for following up on outstanding claims regularly. The general guideline for the steps to be followed includes: 1. About 4-6 weeks outstanding Phone call to the Third Party Insurer to remind them of outstanding claim. 2. About 8-10 weeks outstanding - Letter to Third Party Insurer to remind them of outstanding claim include copy of original invoice. CC the relevant Physician/Physician Assistant/Nurse Practitioner. See Appendix B letter template - Reminder to Insurer (Step 2). 3. About 12-14 weeks outstanding - If claim still not received, then advise Physician/Physician Assistant/Nurse Practitioner in writing that claim remains outstanding and that the claim will be written off. This memo IS NOT sent to the Insurer. See Appendix C memo template Notice of Write Off to Provider (Step 3). NOTE: Claims rejected by Third Party Insurers should be indicated on the Claims Received Report and rejected. If the claim is received after the claim has been written off it should be processed as a newly received claim and recorded on the Claims Received spreadsheet. Finance will provide the Specialist with a monthly Third Party revenue and expenditure tracking sheet which will provide current information by site. This tracking sheet will identify the total cumulative funds available in the central revenue account to be accessed and spent by the WRHA Direct Operation sites and Quick Care Clinics. This tracking sheet will be shared for planning purposes with both Directors responsible for Primary Care Services and Team Managers. Each WRHA Direct Operation site and Quick Care Clinic may access funds from the central revenues account via a request to the after first discussing requirements with their respective Primary Care team and Director responsible for Primary Care Services (where applicable). Program approval for spending of Third Party funds is required in advance of any purchases being made. Funds may also be allocated at the discretion of PC Program Team and/or in consultation with the Director responsible for Primary Care Services. The process for allocating funds amongst the WRHA Direct Operation sites and Quick Care Clinics will be fair and based on need. It is the site responsibility to determine their needs and make a submission. All funds in the central revenue account must be spent

5 of 6 before fiscal year end annually. Funds remaining in this account at year end will not carry forward. APPENDICES: APPENDIX A - Third Party Tracking Spreadsheet excel workbook with two worksheets Claims Received and Claims Outstanding APPENDIX B - Reminder to Insurer (Step 2) Letter template that can be formatted onto clinic letterhead APPENDIX C - Notice of Write Off to Provider (Step 3) Internal Memo template to be formatted onto clinic memo APPENDIX D - WRHA Acute, Long Term & Community Care Sites Fee Schedule for Patient Information SOURCES/REFERENCES: Offset Revenues Binder includes minutes and documentation related to historical discussions on third party recoveries since September 2004 Verbal discussion between T Lynch and H Madden, Sept 28, 2007 regarding processes between sites and Finance Consultation with WRHA Primary Care Direct Operation Clinic Team Managers October 2007, November 2011, and October 2013 Revisions to process at Primary Care Operations Team Meeting, March 25, 2008 review of process between Team Manager and Finance representatives Consultation with WRHA Finance and Program November 2011 and October 2013 Green Belt LEAN Project, Third Party Billing July 2013, Quality Improvement Project Report Out. LEAN Project Team consisted of Sylvie Roman (Project Lead), Louis Sorin (Community Area Director - Point Douglas), Christie Houston-Klatt (Team Manager - 601 Aikins), Linda Mallen (Manager Facility & Support Services - Point Douglas), Sarah Dela- Cruz (Senior Primary Care Assistant - 601 Aikins), Kevin Mozdzen (Primary Care Specialist), Alicia Tuquero (WRHA Finance), and Diane Mazur (WRHA Finance).

6 of 6 WRHA Acute, Long Term & Community Care Sites Fee Schedule for Patient Information, revised date December 29, 2011 Billing for Uninsured Services: A Practical Guide for Manitoba Physicians - Doctors of MB (not to be posted online. Last updated Aug 2010. NOTE: Jan 2015 - WCB new rates entered into EMR Billing as per Cheryl Bezte, Administrative Assistant to: R. Jamieson, I. Foster, M. Venton and B. Kalichuk Doctors Manitoba and Lisa Rempel, CSIS Data Analyst PRIMARY CONTACTS: Kevin Mozdzen - Specialist Jo-Anne Kilgour Specialist ALTERNATE CONTACT: Margaret Kozlowski, WRHA Director, Family Medicine-Primary Care Community SCOPE: Applicable to all WRHA Primary Care Direct Operated Clinics and Quick Care Clinics.