ASCs run lean operations and typically can afford to employ only a small office staff to conduct its business office operations. Problems can be created when one or two individuals are entrusted with the ASC's financial health. Due to limited resources, it is not unusual to discover that the employee who posts the payments to patient accounts also generates the deposit, delivers the deposit to the bank and/or generates the daily receipts report. This closed environment creates unnecessary risks for embezzlement, identity theft and deceptive business practices. Here are 12 key steps ASC owners and administrators can take to minimize these financial risks.
1. Begin with separation of duties in the business office. Take the cash control out of the hands of a trusted few and utilize outside resources to ensure security. Create an effective system of checks and balances by actively separating the cash flow processes associated with over-the-counter collections, phone receipts and mail receipts. One person handling multiple aspects of the finances of an ASC can create opportunities for fraudulent activities, which can end up being difficult to detect.
2. Establish a "lock box" through a banking institution to ensure mail receipts from patients and third-party payors are handled in a secure financial environment. Lock box services include retrieval of the mail from a post office box, scanning of the receipts and same-day deposit of the funds to the ASC's designated account. A lock box system is often perceived as an unnecessary expense but its value is in moving the mail receipts function out of the office to free up staff while simultaneously adding a necessary layer of security. Additionally, money deposited via a lock box is more quickly available for use by the facility and creates a seamless funds accounting process. In efforts to "go green" and create greater efficiency on their end, more and more third-party payors are offering the reimbursement option of electronic funds transfers. EFTs function effectively as direct deposits into a facility's designated account. Remittance advice information is typically facilitated through retrieval of reports from the payor's website or mailed to the ASC's remittance address. Create more rapid access to your reimbursement by utilizing a lock box and EFTs.
3. To handle bank deposits from point of service payments, set up a courier service. This way, facility employees are not handling both receipt of the payments and deposits of the collected cash to the facility's financial institution. It is worth it to pay someone who is bonded and insured to pick up cash and checks collected directly at the facility to minimize losses and avoid liability that could occur should an employee be involved in an accident or criminal attempt by an outside party to confiscate the funds intended for deposit.
4. Next, set up a system of checks and balances in your revenue cycle management. Before closing the month, ensure charges have been entered for all cases performed. If there are discrepancies, investigate. Was a cancelled case erroneously reported as performed? Has the documentation required to enter charges been received?
5. Ensure dollars deposited to the bank tie out to the payments posted. If they do not, explore why.
6. Routinely review credit balance reports to ensure refunds are being processed in a timely manner. Do not let credits sit. They create inaccuracies in your stated A/R days and knowingly retaining an overpayment constitutes fraud. Federal payors (e.g., Medicare, Medicaid, Federal BCBS and Tricare) expect providers to self-report credit balances. Failure to do so creates significant liability for an ASC.
7. Perform routine review of A/R over 60 days. Know the timely filing requirements for each of your payor contracts. If a claim is not worked within the designated timeframe, you may be denied the right to pursue reimbursement. When A/R accounts are older than 90 days, know why and how each account is being worked.
8. Track denials from payors. Make sure you trend denials over time to identify glitches in your system and processes. If you have a high initial claim rejection rate, determine what type of information is being routinely missed during the registration process and educate intake personnel to reduce processing delays.
9. Get into the habit of performing internal reviews to ensure adherence to your established policies, procedures, and processes. Notify business office personnel that internal reviews are being conducted to identify if work processes seem to be working for or against them. Fix those areas that are broken.
10. Audit staff compliance with HIPAA Privacy and Security Rules. Listen to how and where staff members discuss patient information. Are employees speaking about patients in the hallways or break room? Are computer screens positioned to prevent viewing by facility visitors? How is credit card information protected?
11. Check the accuracy of insurance verification and registration. Does your system contain data entry errors? Are payments posted in a timely manner? Are your policies related to point of service collections being followed? Are contracts loaded into your system and underpayments/overpayments worked accordingly?
12. At routine intervals, arrange for external audits. At least once a year have an audit of your coding conducted by an experienced coding firm. A good accounting audit will look at your financial practices with the intent of detecting whether or not you are observing sound financial practices. Often external coding and/or accounting audits will reveal small shifts in current practices are needed to close loops appropriately and to thoroughly protect your ASC's assets.
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