New billing and collection guidelines provide assurances for Wisconsin residents that community hospitals take their commitment to providing care—regardless of ability to pay—very seriously.

Wisconsin Hospital Association President Steve Brenton emphasized hospitals have a mission-driven commitment to provide around-the-clock care to persons in need of medical care. "We want to make it clear that Wisconsin hospitals are committed to working to ensure that patients who are uninsured and have a limited ability to pay receive care in a sensible and sensitive way," Brenton said. In 2002, Wisconsin hospitals provided charity care to an average of 518 patients at a cost of more than $485,000 every day. In all, more than 189,000 individuals in Wisconsin received over $177 million in charity care in 2002.

WHA has developed guidelines Wisconsin hospitals are now reviewing that will help them evaluate their current billing and collection practices. The guidelines suggest minimum income eligibility levels for financial assistance, the need to ensure that discounted bills to low-income or uninsured patients are not inconsistent with amounts charged to a typical insured patient, and several specific collection practices that should be avoided. The guidelines are available on WHA’s Web site, www.wha.org.

Health and Human Services Secretary Tommy Thompson said he is pleased with the efforts made by Wisconsin hospitals to make their billing and collection policies readily available and understandable to the public. According to Secretary Thompson, "In February of this year, I assured the American Hospital Association that nothing in the Medicare program’s rules or regulations prohibits a hospital from offering discounts off of charges for uninsured, low-income patients. In just two short months, the Wisconsin Hospital Association has developed a thoughtful, well-reasoned approach to this very problem, and I commend them for their efforts and thank them for the hard work that they’ve done. This new proposal will serve the patients who are served in Wisconsin’s hospitals and the hospitals in Wisconsin well."

In addition to the uninsured, the guidelines state that consideration should be given to providing financial assistance on a case-by-case basis to patients who have exhausted their insurance benefits and/or whose income or assets exceed financial eligibility criteria but face extraordinary medical costs. Hospital financial aid, however, is not to be used as a substitute for employer-sponsored, public, or individually purchased insurance.

WHA Board Chair Charles Shabino, MD, chief medical officer at Community Health Care, Wausau, said in approving the billing and collection guidelines, the WHA Board of Directors recommends that hospitals address three issues:

• Communication of the policy to patients;
• Identification of appropriate personnel to administer the policy; and,
• Administration of the policy fairly, respectfully, and consistently.

"The more the community knows about the billing practices of the hospital, the better. We have nothing to hide; we want our patients to know first and foremost, we are here to help them with their medical needs," Shabino emphasized.

George Quinn, WHA senior vice president, said Wisconsin is different from most states in that all hospitals are required by law to publicly report both the amount of uncompensated care (charity and bad debt) and to make public their policies on how they will treat people who cannot afford to pay. This public information shows that hospitals have procedures to determine a patient’s ability to pay, and nearly all hospitals have a process in place to inform the public about the availability of charity care.

Quinn also pointed out the financial aid provided by the hospital is not a substitute for the responsibility of government to adequately fund coverage for participants in government health care programs, such as Medicare and Medicaid.

"Wisconsin’s Medicaid program continues to pay less then 60% of the cost to treat patients eligible for care. These costs are shifted to employers and individuals, essentially becoming a ‘hidden tax’ on health insurance premiums," Quinn said.

In response to the new EMTALA (Emergency Medical Treatment and Labor Act) rules published on September 9, 2003 and effective as of November 10, 2003, the Centers for Medicare and Medicaid (CMS) released an updated Appendix V of the State Operations Manual that contains new Interpretive Guidelines that are used to investigate complaints of noncompliance with EMTALA.

The September 9, 2003 rule and the Interpretive Guidelines generally promote the more effective provision of emergency care. Highlights of clarifications of the rule that are contained in the updated Interpretive Guidelines include:

• Clarifying that there is no pre-determined ratio based on the number of staff physicians that CMS uses to identify how frequently a hospital must provide on call coverage. The Guidelines also clarify that a hospital may violate EMTALA if it permits physicians to take call selectively for certain patients while the hospital’s coverage for the physician’s particular service is not adequate.
  
• Clarifying that while a physician is on call he or she may also be on call at another hospital or perform elective surgery, if the hospital has a "back-up" policy.
  
• Specifying that an on call physician’s expected response time to a call for emergency screening or treatment should be stated in minutes in the hospital’s policies.
  
• Specifying that for the purposes of triggering an EMTALA obligation, an individual has come to hospital property when the individual has come to any building owned by the hospital that is within 250 yards of the hospital.
  
• Permitting off-campus departments that are not dedicated emergency departments to care for emergency cases in the most effective way rather than requiring that the patient be transferred to the main campus. However, such departments must have policies in place for handling patients with emergencies.
  
• Clarifying that at registration a hospital may collect demographic information, certain insurance information, whom to contact in an emergency, and other relevant information from individuals presenting with an emergency medical condition, so long as that process does not delay screening or treatment, or unduly discourage individuals from remaining for further evaluation.
  
• Clarifying that if an individual presents to an emergency department requesting services that are not for a medical condition, such as preventative care services (immunizations, allergy shots, flu shots), the hospital is not obligated to provide a medical screening examination under EMTALA to the individual.
  
• Clarifying that a hospital’s EMTALA obligation ends when the individual has been admitted in good faith for inpatient services with the expectation that the individual will remain in the hospital at least overnight.

The September 9, 2003 rule can be found in the Federal Register, and a link to the rule is available at www.wha.org/legalandregulatory. Highlights of the rule itself can be found in the September 5, 2003 Valued Voice at www.wha.org/pubArchive/valued_voice/vv9-5-03.htm. A link to the updated Appendix V of the State Operations Manual is available at www.wha.org/legalandregulatory.

• The commitment of Wisconsin’s community hospitals to the uninsured is on display this week with the public release of voluntary patient collection and billing guidelines that assure the public that hospitals remain committed to their historic mission of caring for uninsured patients and treating them with fairness and sensitivity regardless of financial status.

The WHA Board enthusiastically approved these voluntary guidelines in April and endorsed the Confirmation of Commitment initiative currently being spearheaded by the American Hospital Association. That initiative asks hospitals to confirm one of two statements that were part of a recent mailing from AHA and WHA. The first statement confirms that present hospital policies and practices in general meet or exceed AHA/WHA guidelines. The second statement indicates that the hospital is reviewing current policies and practices with that goal in mind.

• Last week’s Employee PRIDE Program was a wonderful event for the 65 employees recognized by their organizations. The PRIDE Program provides an opportunity for every Wisconsin hospital to recognize a "hero" within their organization. Winners and their families are then recognized at a special event that has become a "must attend" for a growing number of WHA members. One WHA senior leader says that the awards dinner has become a highlight of her year.

Importantly, many PRIDE winners are our strongest advocates for health careers …and we all know how important the workforce issue is for Wisconsin hospitals. WHA will soon be sending out PRIDE Program booklets of essays from our award winners. As WHA Vice President of Workforce Judy Warmuth noted last week, "Open to any page and read about our employees’ pride. It will help you appreciate the skill, compassion and dedication of the very special people who are caring for others in every community in Wisconsin."

• We mentioned several weeks ago that WHA and the Wisconsin Collaborative for Healthcare Quality have developed a Memorandum of Understanding that aims to promote a complementary working relationship between the two organizations. The WHA CheckPointSM homepage now includes a hyperlink (www.wicheckpoint.org) that will take readers to a joint letter from Wisconsin Collaborative leader John Toussaint, MD and WHA Chair Chuck Shabino, MD that describes the two organizations’ commitment to work together to improve patient quality.

Steve Brenton
President

Six weeks into the Healthy Wisconsin 2004 campaign, individuals continue to demonstrate their commitment to advocacy. Individuals from Bay Area Medical Center have directed $1,500 to the conduit and $100 to AHAPAC; Bellin Memorial Hospital employees have directed $2,000 to the conduit, $1,000 to the state PAC and $300 to AHAPAC. Individual campaigns are underway at Children’s Hospital, Columbia-St. Mary’s, Community Health Care/Wausau Hospital, ProHealth Care, and Ministry Health Care. The campaign has reached over 50% toward the goal of $125,000.

"The support from individuals in our member organizations is important to build momentum for our statewide efforts in this election year. In addition to getting our individuals involved in advocacy, Healthy Wisconsin helps to keep our health care issues in front of candidates," said Ann Lucas, WHA vice president, external relations and member advocacy.

The 2004 Wisconsin Rural Health Conference is scheduled June 23-25, 2004, at the Kalahari Resort & Convention Center in Wisconsin Dells. The full conference brochure with registration information is included in this week’s packet and is available on the Web site at www.wha.org.

The conference will open with Terry Hill, MPA, executive director of the Rural Health Resource Center in Duluth, Minnesota. Hill will present "Health Care Quality in Rural America" and discuss how rural providers can be leaders in quality improvement, despite limited resources and low volume environments.

Hospital administrators, chief financial officers, management staff, nurse leaders and trustees are encouraged to attend this conference. There will be special trustee education sessions on June 24. The conference has been submitted for long-term care continuing education credits and for ACHE category II credits.

The July 14 seminar "Current Modifier Reporting Requirements… Are You Keeping Up?" will use actual coding examples, physician documentation illustrations and corresponding UB-92 claims forms to demonstrate the correct application of CCI edits, in relation to the use of modifiers. Coding and billing staff, chargemaster and APC coordinators, business office managers and other financial managers should consider attending this event.

The seminar will be held on July 14, 2004, from 9 am to 4 pm at Hotel Mead in Wisconsin Rapids. A brochure and a registration form are included in this week’s packet and on the web site at www.wha.org. Easy, on-line registration is available as well.

The Wisconsin Hospital Association is offering an educational session for public relations professionals and others who have communications responsibilities in hospitals and health systems on July 15 at the Hotel Mead in Wisconsin Rapids from 9 am - 4 pm. This seminar will focus on three important aspects of communications in today’s health care environment:

- Developing Positive Press Relations
- Writing the Crisis Communications Plan
- Communicating During a Disaster: A Tabletop Scenario

Two well-known communications experts will share their expertise with seminar participants. Scott Fagerstrom, communications manager at Northwest Airlines, is an award-winning communications professional whose experience includes serving as a vice president at Hill and Knowlton, one of the world’s top five PR firms. He also served as business editor at several of the nation’s largest newspapers, and as a professor of PR at Chapman University in Southern California. Fagerstrom will teach participants to effectively write for and communicate effectively with the press to develop good relationships.

Fred Bagg, ABC, APR, Fellow PRSA, will lead the group through the process of writing a crisis communications plan. Bagg is one of most sought-after speakers on this topic in the country. Immediately following Bagg’s session, three tabletop disaster scenarios will allow participants to put their knowledge into action. Officer Larry Kamholz, Madison Police Department spokesperson, will participate and help hospital communicators understand law enforcement’s role in the release of information. Officer Kamholz most recently served as the spokesperson in the case of the Audrey Seiler disappearance, which garnered national media attention.

The role of information technology in health care quality and safety improvement is often discussed, perhaps less fully understood. On June 22-23, the University of Wisconsin, UW Health and several allied organizations will sponsor The Digital Healthcare Conference at the Fluno Center in Madison. Highlights of the agenda include:

- Quality Initiatives: Using Clinical IT to Directly Impact Care
- National Health Information infrastructure: Key to the Future of Healthcare
- The Adoption of IT in the Clinical Setting: Is It Possible?

The Shelby County Health System, Harlan, Iowa is seeking a Chief Executive Officer to be responsible for the overall operations of Myrtue Memorial Hospital. Myrtue is a 52-bed progressive rural hospital with swing beds, specialty clinics and home & public health/hospice services. This position also oversees the Shelby County Medical Clinic, an attached physicians clinic housing eight family practitioners, three physicians’ assistants and one general surgeon, and Prairie Rose Mental Health Center, a community mental health center which provides outpatient mental health services as well as prevention and counseling services. A master’s degree in health or business administration is preferred with a minimum of five years experience in health care administration. Send resumes to: Myrtue Memorial Hospital, 1213 Garfield Avenue, Harlan, Iowa 51537, Attention: Administration.

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