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(1) Reference. N/A.

(2) Policy.

(a) It is the policy of town of Cathlamet that there will be a system in place to accurately track and audit the billing procedure to ensure that each ambulance transport is billed appropriately.

(3) Definitions.

(a) “Demographics document” (also known as “face sheet”) refers to the document containing patient information which is provided by the facility receiving that patient.

(b) “Contracted collection agency” means the collection agency the town may from time to time contract with for collection of delinquent accounts for transport fees.

(c) “EIR” (also known as “run report”) means electronic incident report.

(d) “Third-party billing company” means the billing company that the town currently contracts with to bill for transport fees.

(4) Responsibilities.

(a) Various personnel, including emergency medical volunteers or employees and office staff, will be responsible for completing their assigned portion of the billing procedure.

The EMS battalion chief has overall responsibility for ensuring that the billing procedure is completed.

(5) Guidelines.

(a) After each transport is completed, and the patient has arrived at the receiving facility, the person responsible for the patient’s care during transport will obtain a patient demographics document from that facility.

(b) The town, through its third-party billing company, will bill the patient’s insurance as a courtesy to the patient; provided, appropriate forms as required by the insurer have been signed by the patient or the patient’s authorized representative. Upon completion of the transport, the person in charge of patient care shall review the EIR for completeness and electronically enter the EIR into the online system.

(c) 

(i) The person responsible for the patient’s care will deposit the demographics document and any insurance billing documents in the lock box provided for that purpose at the CFD Main Station.

(ii) The EMS billing clerk or his/her designee shall periodically (not less than monthly) electronically access the EIR forms and review the EIR for completeness. Any nonelectronic forms shall be retained in a secure designated location for access by the clerk-treasurer. If the EMS billing clerk notes incomplete billing information on any EIR, the EMS battalion chief shall collect information necessary for appropriate QA/I action. Such QA/I information shall not be discoverable and shall be protected pursuant to applicable Washington state statutes.

(d) 

(i) Upon receipt of the EIR data and any related billing documents by the third-party billing company, all accounts are set up and charges are entered within three days. Once this entry is completed, all charges with sufficient information are billed directly to the appropriate payor, while those accounts without sufficient billing information are billed directly to the patient along with a form requesting insurance information.

(ii) The clerk-treasurer shall perform spot-check validation to ensure the EMS billing clerk is submitting correct and accurate information to the third-party billing company. The clerk­treasurer shall promptly request the EMS battalion chief to investigate any irregularities and to report in writing the results of his/her investigation with the purpose being to determine whether any EIRs have been altered without proper authorization or whether any acts constituting fraud or abuse have occurred. If it is suspected that any acts of fraud or abuse may have occurred, the town will take necessary corrective action, including reporting to the Wahkiakum County sheriff’s office and/or the State Medicaid Fraud Control Division. The clerk-treasurer will report his/her findings to the mayor and council.

(e) Third-Party Billing Company Responsibilities. Items billed directly to an insurance company are reviewed monthly. Rebilling and additional information is provided as necessary. After all appropriate insurance payments have been received, a private statement is generated and mailed to the patient if there is a legally collectible balance.

(f) Patient inquiries shall be referred to the third-party billing company.

(g) Payments are typically mailed directly to the town of Cathlamet and the record of the receipt is forwarded to the third-party billing company for posting. They shall always be made payable to the town of Cathlamet, never to the third-party billing company. Those payments are then deposited in a bank account established by the town clerk-treasurer’s office.

(h) The third-party billing company will inform the town clerk-treasurer in order to initiate any refunds to patients or insurance companies by the use of a “refund request form” along with the supporting documentation. Refunds will be processed through the town’s established voucher process for accounts payable.

(i) As long as a patient has a private balance owing, the patient will continue to receive monthly statements from the third-party billing company until the account is paid in full or it is deemed to be uncollectable. If the third-party billing company has received no payment and no contact from the patient after the second statement is mailed, it will attempt to make phone contact to encourage the patient to set up a payment plan.

(j) For those accounts that result in mail returned, phone disconnection, or no response, the third-party billing company will make a final call to the hospital to see if they have any updated information. Typically, these accounts have already been turned over to collections or written off by the hospital. In the rare situation that the hospital has new billing information, the third-party billing company will follow up with this information.

If no further information is available from the hospital, these accounts are deemed uncollectable. The third-party billing company shall notify the town clerk-treasurer of its determination that the account is uncollectable.

(k) For those guarantors owing $100.00 or more who have not responded prior to the mailing of the fourth statement, a collection notice shall be sent with the fourth and final statement. This notice includes a date by which the patient must respond to avoid collections. If no response is forthcoming, the account will then be returned to the town for follow-up and adjustment off the accounts receivable. If the town has no correct address the account is sent directly to the contracted collection agency without this notice. Those accounts of $99.00 or less are adjusted off the accounts receivable. A list of patients deemed uncollectable shall be made available in the monthly reports sent to the town clerk-treasurer by the third-party billing company.

(l) If a patient has returned an indigent care application to the third-party billing company’s office it is forwarded to the town clerk-treasurer with any other pertinent information they have regarding this account with a recommendation. The town will review the indigent care application in accord with its established indigent care policy.

(m) Once per month, after the final charges for the month have been entered, the third-party billing company will generate the monthly private statements, age the account receivables and produce the monthly reports, which are sent to the town clerk-treasurer. These reports will detail the monthly activity on the town’s accounts. For accounts which have been adjusted off the account receivables under subsection (5)(k) of this section, or which are deemed uncollectable or authorized for write off under subsection (5)(i), (5)(j), (5)(k) or (5)(l) of this section, the clerk-treasurer and EMS billing clerk shall sign an authorization to write off the account. Accounts to be written off will be submitted to the town council for final approval by formal resolution of the council. Submission to the town council shall occur not more than every 12 months.

(n) It should be emphasized that these are guidelines. Because the third-party billing company works closely with the patients and the town staff to resolve billing issues, there will be situations which require a reasonable degree of flexibility.

(o) All identifiable care information shall be safeguarded in strict compliance with the security and privacy rules contained in HIPAA and the Washington State Health Care Information Act, Chapter 70.02 RCW, and the administrative rules and regulations promulgated pursuant to those statutes.

(6) Additional References.

(7) Appendix. N/A. (Res. 384 § 3, 2020)