Billing and Collection Policy
It is the policy of Blue Cube Medical to pursue collection of our clients’ balances from clients who have the ability to pay for the services we provide. Blue Cube Medical will make reasonable efforts to identify clients who may be eligible for discounted services or payment plans. Collection procedures will be applied consistently and fairly for all clients regardless of insurance status. All collection procedures will comply with applicable laws and Blue Cube Medical’s mission. For those clients who are unable to pay all or a portion of their invoice, the applicable Financial Policy or Charity Care policy will be followed.
Collection agencies and law firms may be enlisted after all reasonable collection and payment options have been exhausted. Agencies may help resolve accounts where clients are uncooperative in making payments, have not made appropriate payments or have been unwilling to provide reasonable financial or other data to support their request for payment arrangements with Blue Cube Medical. Collection agency and law firm staff will uphold the confidentiality and individual dignity of each client. All agencies and law firms will comply with all applicable laws including HIPAA requirements for handing protected health information.
This policy establishes reasonable procedures regarding collection of client accounts, including actions that may be taken by Blue Cube Medical or contracted external collection agencies and law firms.
This policy applies to Blue Cube Medical, all affiliated corporations and partners, and business associates (BAs).
Extraordinary Collection Actions
Actions that Blue Cube Medical may take, or authorize a collection agency or law firm to take, related to obtaining payment of an invoice or bill for patient financial assistance and/ or advocacy services include the following:
1. Deferring, denying or requiring a payment before providing services because of an individual’s non-payment of one or more invoices or bills for previously provided services;
2. Actions that require legal or judicial process including, but not limited to:
1. Commencing a civil action or lawsuit against the client including, but not limited to;
2. Garnishing an individual’s wages after securing a court judgment;
3. Attaching or seizing an individual’s bank account, other personal property, or other judgment enforcement action permissible under state law after securing a judgment;
4. Placing a lien on an individual’s property after securing a judgment provided that placing a lien against an individual’s personal recovery, settlement, compromise or judgment is not considered an extraordinary collection action (ECA).
Placing a client’s account with a collection agency is not an extraordinary collection action.
Blue Cube Medical Reasonable Efforts to Identify Clients Eligible for Financial Assistance
1. Provide written notice to the individual indicating that financial assistance is available to eligible individuals, indicating that Blue Cube Medical intends to initiate or have a third party initiative to obtain payment for the services, and provides a deadline after which ECAs may be pursued and which is no later than thirty (30) days after the date of this written notice;
2. Provide the individual a Plan Language Summary of the Financial Assistance Policy with this written notice; and
3. Make reasonable efforts to orally notify individuals about the Blue Cube Medical financial assistance policy.
ECAs for services will not commence for a period of 90 days after the date of the first date of services that were performed by Blue Cube Medical.
Financial Assistance Application Period
The financial assistance application period begins on the date Blue Cube Medical first provides patient financial assistance and/or advocacy and ends 90 days after the same date.
Identification of Reasonable Efforts Taken
Prior to engaging in ECAs, Blue Cube Medical’s revenue cycle staff will identify whether reasonable efforts were made to determine whether an individual is eligible for financial assistance. The Blue Cube Medical Compliance Officer will provide oversight for identification of reasonable efforts made.
Consistent with this Policy and the Financial Assistance Policy, Blue Cube Medical will clearly communicate with clients regarding financial expectations as early in the Patient Financial Assistance and Advocacy services providing process as possible.
· Clients are responsible for understanding their insurance coverage and for providing needed documentation to aid in the insurance collection process when providing patient financial assistance and advocacy in order to aid in the insurance collection process.
· Clients may be required to pay a pre-service deposit or estimated co-pays and deductibles prior to services
· Clients are generally responsible for paying balances, including any amounts not paid by insurance companies or applicable third-party payers.
· If the patient has a previous bad debt or outstanding balance, Blue Cube Medical may request amounts owed before future appointments are granted. If arrangements cannot be made for resolving the client’s outstanding balance, future services may be limited or denied. Pre-service deposits may be required for service.
Blue Cube Medical may pursue legal against clients who obtain the benefits of services provided by Blue Cube Medical and refuse payment for said services. These refusals include chargebacks, direct refusal to pay for services rendered, and other false claims for services not rendered by Blue Cube Medical. Legal follow-up and commencement of a lawsuit is appropriate and permitted subject to the following:
· Authorization to take legal action against a client for the collection of debt and will be provided on a case-by-case basis
· Legal action will not be filed against any particular client to collect debt until Blue Cube Medical determines that:
o There is a reasonable basis to believe that the client owes the debt,
o Where the client has indicated an inability to pay the full amount of the debt in one payment.
It is the policy of Blue Cube Medical, through adoption of this Policy by the applicable governing staff and Board of Directors of Blue Cube Medical, that this Policy will be enforced for all collection staff, collection agencies, and attorneys. Any abusive, harassing or misleading language or conduct by its employees responsible for collecting debt from clients and from its debt collection agencies and attorneys and their respective agents and employees will be addressed through corrective action procedures.
When making decisions throughout the collection process, Blue Cube Medical is committed to upholding the multiple federal and state laws that preclude discrimination on the basis of race, sex, age, religion, national origin, marital status, sexual orientation, disabilities, military service, or any other classification protected by federal, state or local laws.
Blue Cube Medical staff will uphold the confidentiality and individual dignity of each of our clients. Blue Cube Medical does and will meet all HIPAA requirements for handling personal health information.