Billing services policy

Last reviewed January 2024

Purpose

To ensure all billing processes are consistent with the Attorney General agreement.

Policy

Welia Health will ensure patients are appropriately and timely billed for services rendered.

Procedure

  1. Welia Health has zero tolerance for abusive, harassing, oppressive, false, deceptive, misleading language, collections conduct by its debt collection attorney and agency, and their agents and employees, and Health System employees responsible for collecting medical debt from patients.
    • a. The Welia Health’s Board of Directors shall review, at least one time per year, the Health System’s practices in the following areas:
    • b. The filing of debt collection litigation against Health System patients, including the garnishment of patient wages or accounts subsequent to entry of a default judgment.
    • c. The debt collection activity of its third-party debt collection agencies.
    • d. The debt collection activities of its internal debt collectors.
    • e. The Health System’s compliance with the Agreement with the Attorney General and the policies described in Section II of this policy.
    • f. The results of the reviews required by the CEO in Litigation Practices, Section III and Collection Agencies Policy, Section I.
    • g. The results of the audits required in Section X of this policy.
    • h. The Health System Charity Care practices
  1. The Health System has developed and implemented procedures to ensure the timely and accurate submission of claims to third party payers. If the Health System timely received from a patient, information about the patient’s third-party payer but does not timely submit a claim to the third-party payer, the Health System shall not bill the patient for any amount in excess of that for which the patient would have been responsible had the third-party payer paid the claim. The Health System shall not refer any bill to a third-party collection agency or attorney for collection activity while a claim for payment of the bill is pending with a third-party payer with which the Health System has a contract. The Health System may refer a bill to a third-party collection agency or attorney following an initial denial of the claim by the third-party payer. The Health System shall not refer any bill to a third-party collection agency or attorney for collection activity when a claim is denied by a third-party payer due to the Health Systems error, and such error results in the patient becoming liable for the debt when they would not otherwise be liable. The parties recognize that, in order for the Health System to properly bill a patient’s insurance company, the Health System may need the patient’s cooperation and that the Health System may not be able to properly bill the patient’s insurance company without the patient’s cooperation. In the event that the Health System believes that a private third-party payer has improperly delayed or denied payment of a claim, the Health System may file a complaint with the Minnesota Attorney General’s Office, which may provide assistance or its patient in attempting to get the claim paid.
  1. The Health System shall develop a streamlined process for patients to question or dispute bills, including a toll-free phone number patients may call and an address to which they may write. The phone number and address shall be listed on all patient bills and collection notices sent by the Health System. The Health System shall return telephone calls made by patients to this number as promptly as possible, but in no event later than five to seven business day after the call is received. The Health System shall respond to correspondence sent to this address by patients within ten (10) days.
  1. If a patient advises the Health System, its debt collection agency, or any attorney utilized by the Health System that: a) the patient does not owe all or part of a bill, b) a third party payer should pay the bill, or c) the patient needs documentation concerning the bill, the Health System, the collection agency, and its attorney must cease further collection efforts until the Health System or the agency provides the patient with documentation establishing that, as applicable, the patient owes the debt or that the applicable third party payer has already paid all amounts for which it is obligated. The Health System or the collection agency shall provide such documentation in writing within ten (10) days and shall not pursue further collection activity for a period of thirty (30) days after providing proof that the debt is owed, so as to give the patient further opportunity to pay the bill or to challenge the documentation supplied by the Health System. If the Health System provides the required documentation and the patient does not respond within thirty (30) days, the Health System may resume collection activity.
  1. The Health System has developed a system to record and log all patient complaints received by its billing offices, including at the locations identified in Section V of this policy, regarding the collection of medical debt by the Health System or its third-party debt collection attorneys or agencies.
  1. If the Health System demands that an uninsured patient pay a medical bill, the Health System shall provide to that patient a detailed, itemized bill as part of the billing process.
  1. The term “most favored insurer” means the nongovernmental third-party payer that provided the most revenue to the provider during the previous calendar year. The Health System shall not charge for any uninsured treatment in an amount greater than the amount which the provider would be reimbursed for that service or treatment from its most favored insurer. The total charge for uninsured treatment shall not be more than the provider would be reimbursed directly from its most favored insurer and from that insurer’s policyholder under any applicable and allowable copayments, deductibles, or coinsurance. The Health System shall apply the same percentage discount to its charge description master for uninsured treatment that it would apply to charges incurred by a policyholder of its most favored insurer. Beginning on the date of the Agreement with the Attorney General, each year the Health System and the Attorney General may agree in advance, by a confidential letter agreement, on the percentage discount from the charge description master that the Health System provides to its most favored insurer and which the Health System shall provide for uninsured treatment under this paragraph. The Health System shall provide to the Attorney General, any information requested by the Attorney General for purposes of calculating this discount. The Health System shall utilize the same initial charge description master prices for uninsured treatment that it utilizes for treatment provided to a policyholder of its most favored insurer.
  1. The term “uninsured treatment” means any treatment or services which are not covered by a plan, contract, or policy which provides coverage to the patient through or is issued to the patient by: (1) a “health plan company,” as that term is defined in Minn. Stat. § 62Q.01, subd. 4; (2) a self-funded employee benefit plan; (3) any governmental program, including but not limited to MinnesotaCare, the Minnesota Comprehensive Health Association, Medicare, Medicaid, or TriCare; (4) any other type of health insurance, health maintenance, or health plan coverage; (5) any other type of insurance coverage, including but not limited to no-fault automobile coverage, workers’ compensation coverage, or liability coverage. In the event that the Health System inadvertently sends a bill to a patient in excess of that which is allowed by this paragraph 33 because the Health System is not aware that the treatment or service constitutes uninsured treatment, and the Health System thereafter learns that the treatment or service constitutes uninsured treatment, the Health System shall promptly adjust its charges so as not to exceed the amount allowable under this paragraph 33, and the Health System shall promptly notify the patient of the new amount of the bill.
  1. This paragraph shall only apply to charges by or incurred at a facility defined in Minn. Stat. § 144.50, subd. 2 (2004) or Minn. Stat. § 144.55, subd. 2 (2004), including those of a provider who is employed by the Health System when providing services to a patient at a facility defined in Minn. Stat. § 144.50, subd. 2 (2004) and Minn. Stat. § 144.55, subd. 2 (2004). This paragraph shall only apply to medically necessary health care treatment and not to cosmetic procedures without any medical necessity.

In recognition that some patients express their finBusiness Office; Financeancial concerns directly to their treatment providers (i.e., doctors, nurses, etc.), the Health System shall train its staff responsible for admissions, billing, and providing direct patient treatment, about the existence of the Welia Health’s Benefit Program and how a patient may obtain more information about the Welia Health’s Benefit Program or submit an application.

SectionBilling Service PolicyEffective Date
ContactBusiness Office; FinanceLast ReviewOctober 2023
Approved byGoverning Board
Policy & Procedure Committee		Next ReviewOctober 2024
ReferenceApproval DateOctober 2022
DestinationBusiness Office; Finance

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