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Highlights from the Compliance + Ethics = Integrity Podcast

In this recent podcast, BerryDunn’s Robyn Hoffmann, Senior Compliance and Credentialing Manager in BerryDunn’s Healthcare Practice Group, Denny Roberge, Senior Manager in BerryDunn’s Healthcare and Not-for-Profit Practice Groups, and Roger Rego, Revenue Cycle Manager in BerryDunn’s Healthcare Practice Group, discuss the revenue cycle implications for the end of the Public Health Emergency.

Highlights from this episode:

• Collecting patient information at the time of scheduling
• How EHRs (Electronic Health Records) can help with your workflows and decrease denials
• The importance of proactively educating patients
• Working collaboratively as a revenue cycle team

Below is an edited transcript of the podcast. Listen to the full episode here. 

Robyn Hoffmann: It’s my distinct pleasure to introduce my colleagues. I'll start with Denny Roberge, who is a recognized subject matter expert on revenue cycle and patient access transformation, revenue integrity program management, and back-end revenue cycle redesign. Denny, you've been called upon to share your revenue cycle expertise with various chapters of the Healthcare Financial Management Association, and also with the mid-Atlantic region of the National Association of Healthcare Revenue Integrity. And it's my pleasure to also introduce my colleague, Roger Rego. Roger, you bring to BerryDunn over 30 years of experience from the not-for-profit healthcare sector. You've worked as a Chief Financial Officer at a Federally Qualified Health Center (FQHC). You've worked in hospital settings and you've also worked for Medicare and for TRICARE.

Denny, I saw you were the author of what was a really wonderful article for BerryDunn, which was published back in March 2020. The title of that article was “Preparing Your Revenue Cycle for the Pandemic – COVID-19.” Now the pandemic has finally ended. With the end of the Public Health Emergency and the unwinding of Medicaid continuous eligibility, can you give our listeners some examples of the impacts on what we at BerryDunn refer to as the “schedistration” segments of revenue cycle?

Denny Roberge: Certainly, a lot has changed in terms of the healthcare landscape from the payer side, provider side, all throughout it. It’s been a really challenging time. But when it comes back down to it, we think about our revenue cycle and the challenges that we had pre-, post-, and during the pandemic, we've always had issues in and continue to have the issues around making sure that we're getting the right demographic and insurance information so that we can:

• Bill correctly
• Eliminate the denials
• Eliminate patient frustration from getting bills that they don't deserve

When we talk about “schedistration,” that's really combining two processes that are often disjointed: the scheduling event and the registration event. There are plenty of different ways you can structure a revenue cycle on intake, but ideally, you really can't start a good financial clearance process unless you have the basic information you need, and the best time to do that is when you have the patient in need of a service and on the phone. So, when we talk about “schedistration” and those types of things, it's really combining that scheduled event or the earliest event possible in your revenue cycle to start getting the information you need to start processing that patient.

And by processing, I mean verifying that, in fact, the information they gave you from the insurance company is correct. From there, if there is a patient balance, making sure that they're aware of it, having those discussions, or if they qualify for charity care or other programs, assisting them in finding that. If the service requires authorization, the time to do it is as soon as you can start really working on that patient, which is the scheduling event most of the time. And again, sometimes even at an ordering event, you can start the same process.

But to your point, you know now that we're in this post-pandemic era where we've got a new challenge, right, the Medicaid eligibility criteria are rolled back now. So, it comes back to:

• You're not going to get paid if you bill the wrong insurance
• If a patient doesn't have the means to pay, you're also not going to get paid

Looking forward—or backwards, I should say, in the revenue cycle continuum to really make sure we understand that patient’s financial obligations, what they have for insurance. If they just lost their Medicaid or what is available to them, and the only thing that's available to them is charity care, then enroll them in the charity care program. That's what they're there for, right? Or in the FQHC space, the sliding fee schedule. That's what's best for the patient and it's also what's best for your revenue cycle, so you're not spending time and effort trying to find dollars that aren't there. And so again, this is where getting it right up front really makes a difference. And so, “schedistration,” as soon as you can start getting that information and clearing that patient, is essential. Right now, we've got that new challenge because a lot of insurances are changing for a really vulnerable population.

Robyn Hoffmann: I'd like to turn to Roger now, who has worked as a CFO in an FQHC. And I'm wondering, should there be any changes in the design of a healthcare organization’s internal reports due to the unwinding of the Medicaid continuous eligibility? Would there be a need to increase the frequency of generating internal reports to identify whether your organization might be heading toward some losses in reimbursement?

Roger Rego: With the unwinding of this emergency, and the Medicaid coming out, now, it's even that much more important because we've had the last two-and-a-half, three years where Medicaid was much more available to people. With that rolled back, it's going to really make a demand on the whole revenue cycle, especially in the back end. Like you said, it's very important to get all that information upfront, but we know that there are times when that doesn't happen.

Then the responsibility comes to the back end who is seeing it. Unfortunately, by the time they see it, it’s too late and, especially in the Medicaid world, if a person lost Medicaid, maybe that patient doesn't even realize it. It's important that not just one person or that your billers are the ones watching for denials, you want a team to be meeting on a regular basis. Bring a team together that has the whole revenue cycle: your patient access coding, your departments, your IT, your business office, and work through those reports as a team and take a look at what's causing your denials. There's going to possibly be more opportunity to see denials increasing on the Medicaid side, which, if you're not being proactive or not getting your patient signed up for charity care or sliding fee scales, it's going to be hard for collections and it's just going to be hard for the organization.

Robyn Hoffmann: Denny, because you are so knowledgeable about EHR systems, is there any way that the EHR can be used to help to inform patients about these imminent changes?

Denny Roberge: The good thing with the EHR technology is most of them integrate to and from the payers, you know, the 27X responses. It can bring you a lot of information about their eligibility, term dates, and so forth. Again, for me, the best practice has always been to start financially clearing the patient ahead of time, and this is where the EHR can become a tool of real value.

If you select your EHR correctly—if your EHR doesn't have the functionality, there are plenty of bolt-on companies that can assist, and the value of it is well worth any cost. You can create a workflow where, as soon as the patient is scheduled, you start verifying their benefits, and at that point you'll know if they'll be eligible or not for their upcoming visit.

You can use that response to reach back out to the patient and engage them in the charity care process, sliding fee process, and/or enroll them in an alternative plan. There are a lot of different ways you can reach out to a patient with these tools, technologies, and workflows and be assured that if you follow the right workflow, that the patient has coverage and that you're not going to have any issues on the back end. These processes can be heavily automated so that your team is only looking at the exceptions. So, if I register and I'm good, I'm green, you don't have to worry about me. And if you come back red, it tells you that no matter what you do on the back end, you're not going to pay—you're not going to get paid because that patient’s registration is incorrect, and those are the ones you should focus all your effort on. I’m a big advocate of setting up the workflows within your EHR and, to me, that is the only way you can officially and effectively create a best practice front end.

Robyn Hoffmann: Roger, do you have any thoughts about this in terms of ways that healthcare organizations can inform either their established patients or new, and are shopping for a new primary care provider, about the unwinding of Medicaid? Are there ways that you would recommend organizations take action in addition to all of the EHR opportunities that Denny has offered?

Roger Rego: Within your EHR, you can run a report that lists all your Medicaid patients. So, you could go through that report and do an eligibility check on all the people who are established patients. If you identify people who have lost Medicaid, instead of waiting for them to come in, you can actually start reaching out to them now. That way you're going to be able to change what's in their demographics and they're going to be pretty happy that you're contacting them to walk them through the process.

You want staff to be educated on Medicaid, what this all means, and the changes that are happening and be able to explain that to the people ahead of time. It’s really critical to be doing that for new patients. What if they're out there looking for a new provider? You can let them know about the end of the COVID emergency and changes in Medicaid enrollment using your website, using Facebook, using Twitter, and any other means that you have to reach out to patients. I would recommend that for any changes within your organization that impact patients. Even your established patients are going to look at your website. Sometimes they're going to make an appointment there. Sometimes they're looking to see what specialists there are, so I mean, it's a great way to educate patients on the different changes.

Denny Roberge: That's great, Roger. And I know Robyn was asking for our final thoughts about the end of the pandemic and what we think organizations should be looking at and doing. There's been a lot of change since the pandemic began, and those changes are things that we learned to adapt to quickly. We learn to respond to things. And those skills we learned, I think we have to make sure we keep them sharp and continue to focus on the commercial and the government regulations because the commercial payers are probably going to start pulling back on a lot of different things that they allowed around telehealth and coverage.

You really want to make sure you're monitoring your commercial payers, monitoring Medicare, because we're in a new period. I think rapid change and the kind of change we've seen in the past is here to stay. It's going to be on us, as providers, to stay on top of things and we have to be proactive and not reactive if we really want to make sure that our revenue cycles are healthy. Those would be my parting words: just keep up the nimbleness and willingness to change. Those are going to be the guiding strengths that help you and your organization succeed and remain strong in the future months.

Roger Rego: That's great information, Denny and to follow up on that, the important thing is to be really working as a team. Because if one department identifies something, and they're not talking to anybody else, it's just not going to work. It's really important that you're working together as a revenue cycle team: front end, middle, back end, it's all the same. The key piece is to just keep working together, stay on top of it, and watch for changes. When you identify changes, get it out to everybody in the organization and make sure they're aware of it.

Robyn Hoffmann: Denny and Roger, thanks again for sharing your insights. We've reached the conclusion of our discussion about the impacts of the close of the COVID-19 Public Health Emergency on revenue cycle operations and the unwinding of the Medicaid continuous eligibility provision. We welcome your questions and feedback about the ideas we discussed, as well as suggestions for topics that we should consider developing for future episodes.

Disclaimer: The content we discussed is based on our professional experience advising healthcare providers, facilities, and other organizations that engage BerryDunn for compliance and other services. While we may reference specific government programs, Medicare and Medicaid policies, and regulatory guidance, we do not speak for any government agency or contractor, nor do we have the authority to do so. Nothing in this podcast should be considered legal advice. Anyone seeking legal advice on the subjects we discuss should consult their own attorney.

As an audit committee member, your role is critical to helping ensure the integrity and transparency of the company's financial reporting and internal controls. To perform your duties effectively, it's important to have a clear understanding of your responsibilities and to regularly assess your committee's performance. Beyond the obvious financial knowledge, there are some basics to consider about how your audit committee is run, and what it focuses on, that can make a big difference in its effectiveness.

1. Are your audit committee meetings effective?

Audit committee meetings are the heart of your audit committee. But are you making the most out of them? Successful committees meet on a regular basis, and members take their responsibilities seriously and do what they can to prioritize attending the meetings. An effort should be made to develop a comprehensive agenda and supporting materials for the committee’s review in advance of all meetings. A member should be delegated to take thorough and accurate minutes that are distributed to the committee, and communication with other committees and the board should be on a regular cadence.

2. Is your chair prepared to lead the committee effectively?

The chair of your committee plays an important role, so it’s necessary that you have guidelines in place for selecting your chair, preparing them for their role, and evaluating them. Be sure that you have a process outlined for selecting and transitioning to a new chair. How are they identified and prepared for the role? What skills and knowledge will a chair need to effectively lead the committee? These should be documented, along with rules about conflicts of interest and independence that need to be considered.

3. Do you have a comprehensive onboarding and education program for your committee?

Not all members coming on to the committee will be knowledgeable about the company or what is required of them as a member of the audit committee. You should have a comprehensive onboarding program for any new members to educate them. In addition, providing ongoing training and education opportunities for all committee members to enhance their knowledge and skills, or even mandating certain continuing education requirements, can help ensure that members have the knowledge needed to effectively fulfill their responsibilities.

4. Are you evaluating how ethics and compliance affect your organization?

Given the committee’s role in helping ensure the integrity and transparency of the company's financial reporting and internal controls, it is your responsibility to ensure policies and procedures are in place for reporting and dealing with any ethics or compliance issues. This begins with evaluating how management is setting the tone for ethical behavior and compliance with laws and regulations, and how the culture of the organization either supports or does not support ethical and legal behaviors. Getting into more specifics, are employees encouraged to speak up if they observe unethical behavior? Is there a clear process for reporting and addressing potential violations? Are whistleblower policies and procedures in place and understood? Are reports promptly and thoroughly investigated? Implementing these policies is a critical step in helping your organization minimize risk and stay compliant with regulations.

5. Is risk management a top priority?

Beyond ethics and compliance issues, there are a number of other risks that your committee needs to keep its eyes on. The first step is to be clear about which risks the committee is responsible for monitoring and how those risks are communicated with the board. At a basic level, the committee should be familiar with the company’s risk management process, including its Enterprise Risk Management program. The committee should also fully understand any changes in the regulatory environment and how those changes may impact the company. Finally, attention should be paid to compensation incentives that could create a risk for financial reporting.

If you can answer the five questions above with a “yes,” your audit committee has a firm grasp on its responsibilities and has clear procedures on how the committee is run and what its priorities are. On the other hand, if you answered “no” to one or more questions, now you should have a good idea of where to focus to make your committee more effective.

If you have questions about setting up an audit committee or need assistance with internal controls or internal or external audits, our team would be happy to speak with you.

Healthcare system conversions are risky endeavors. But what is the alternative? Stay with a system you’ve outgrown and no longer meets your organizational needs? At BerryDunn, our healthcare consulting teams have worked with a substantial number of organizations as they’ve transitioned to new enterprise systems such as Electronic Health Records (EHR) systems and Enterprise Resource Planning (ERP) systems. Based on our experience, there are 10 key areas to focus on in order to have a successful conversion.   

1. Start preparing early 

If you know you’ll be bringing in a success partner like BerryDunn to help you through the conversion, bring them early in the planning as possible. The success of the entire project depends on how well you’ve planned and if you've brought in a strong methodology to approach the implementation.   

2. Assess your needs before you make a decision to change systems 

Before you even decide that you need a new EHR or ERP system, the first step is to conduct a thorough assessment of your current system and determine if you actually need a new system.  It’s possible that your current system could and will meet your needs if set up correctly.  

If you determine that you do need a new system, the next step is to conduct a thorough needs assessment that details exactly what your organization needs out of the system. It’s important not to think in terms of what your old system was capable of, but to focus on the problems that you want the new system to solve. Talking to other organizations or consultants like BerryDunn, who are solely focused on and have experience in this work, can help you determine what best-in-class systems can do.  

3. Understand and mitigate the risks 

There are risks at every stage of the process, from not identifying your needs correctly, not assessing the facility’s readiness for change, choosing a subpar vendor, having an incomplete contract, not monitoring the implementation very closely to meet the deadlines, and not addressing the risks as they appear. It’s important to manage the steps correctly at each phase, beginning with: 

• Documenting detailed requirements for the EHR or ERP system 
• Initiating a formal RFP process to include the system requirements in writing 
• Thoroughly vetting and evaluating vendors consistently 
• Negotiating a solid contract that holds the vendor accountable for support and a timeline 
• Assessing what staffing changes and training are needed 
• Providing sufficient time for testing pre- and post-go-live 
• Understanding and planning for the impacts to your revenue cycle 

4. Manage the vendor 

The vendor may be managing the project, but who is managing the vendor? Whether you hire a consultant like BerryDunn or have in-house resources, managing the vendor can be a full-time job. In our experience, the vendor wants to have a successful implementation as much as you do, and they also want to go live on time so they can move on to their next project. You will need to advocate for your organization and be able to hold the vendor accountable to what was agreed on, even if that means taking more time. If your contract was thorough, you should have enough leverage to do so. The bottom line: Don’t feel rushed to go live until you know you are ready. 

Insist on a detailed implementation plan from the vendor that shows realistic timelines for the tasks needed to be accomplished to meet the go-live date. The project should include weekly communication meetings with the vendor to ensure any problems and delays identified can be addressed quickly. 

5. Make sure your internal project team is ready 

Just as it’s important to ensure your vendor is well-staffed, prepared, and held accountable, these factors are equally important for your internal project team. Take the time at the beginning of the project to create a plan for success that takes into account roles, communication, and contingency plans. A good plan will include:  

• Establishing a project charter to formalize governance, teams, and roles and responsibilities 
• Communicating and reinforcing the project as a mission-critical effort 
• Establishing regular project meetings to follow up on and manage risks, actions, issues, and decisions 
• Monitoring competing priorities and alleviating non-project efforts for staff where possible  
• Anticipating project team turnover and having a plan for backfilling team members in advance 

6. Help your staff adopt the new system 

Even if you implement the best system in the world, if your nurses, doctors, and billing staff don’t use it (or don’t use it correctly), it won’t be effective. You need to be able to manage the people side of change, starting with building the case for why you are switching systems and how it will benefit the working staff. Having a thorough training plan and making sure people are ready for the conversion is a key step that shouldn’t be neglected. 

7. Allocate enough time and the right resources for testing 

Before you go live, you need to know the system is going to work for specific scenarios in every department that uses it. For EHR systems, that is every department that touches a patient. A solid testing plan begins with identifying the key, critical scenarios in each area and assigning the right people to be involved in testing – ideally, those who will be using the new system and have a firm grasp on the typical workflows. The plan should “follow” a patient from the point of registration to treatment, discharge, billing, and patient follow-up. A good testing plan will confirm if the system functions as intended and will drive issue resolution and any needed configuration changes. Ultimately, the result of testing will be to determine if you’re ready for go-live.  

8. Get your accounting systems in order  

Many healthcare organizations implement new accounting ERP systems at the same time they convert their EHR. It is important to determine concurrently how the operational and financial data from the EHR will be integrated into the general ledger and reporting dashboards. A study will need to be made on the ease with which the payroll information from the outside software application can be accurately uploaded. Your chart of accounts likely will need to be revamped.  Electronic invoice routing and approvals have become very sophisticated and can improve efficiency with the proper setups. Your new accounting ERP system should not be a “last minute thought” but carefully selected and planned as the EHR is being implemented to ensure accurate and state-of-the-art reporting to deliver to your internal and external audiences.   

9. Don’t neglect your revenue cycle 

Launching a new system is not business as usual. Most new EHRs introduce new complexity to the clinically driven revenue cycle. This requires different management skills and tighter coordination across the organization. Success requires advance planning around charge master structure changes, patient access, and other workflows that will heavily change. Attention needs to be paid to leveraging clearinghouse functionality, and testing plans should incorporate all charging and payor scenarios.  

In addition, no matter how prepared you thought you were, your clinicians are just not going to be able to do things as fast as usual when using a new tool. It takes time to build proficiency in any new system. When launching a new EHR, you’ll need to schedule lighter patient loads in the weeks after your go-live, allowing flexibility for fixing problems and for taking into account learning curves.  

Because of this lighter load, your revenue cycle will be impacted. Fewer patients will be cared for, and fewer patients will be billed. You need to consider these cash flow impacts and plan around legacy receivables well before launch day (ideally as much as two years prior) so you can plan for it and ensure that you’re accounting for, and finding ways around, any shortfalls.  

10. Manage the post-go-live transition 

So you went live with your new system. Congratulations! But this isn’t the end. The two weeks after your go-live date are very important. Are you meeting with the vendor to track defects? Are you getting everything out of the system that you dreamed of? Do you have a plan for addressing deficiencies and adding more functionality? Most vendors have a two-week window to help you post-go-live. You need to take advantage of that while you still have their attention. Once you transition to help desk support, you’re just not going to get the attention that you were before. Having a plan and a system in place for these post-go-live weeks is crucial.  

Is it time to bring in a success partner?  

To be successful, you need a partner who can address all of your needs and be your advocate, and expert, providing the support – and the answers – to questions you might not even know to ask. BerryDunn’s Healthcare team works with healthcare organizations every day, all year long, guiding them through EHR and ERP selection, vendor management, system implementation, testing, and beyond to mitigate risks and help ensure your investment pays off. We’re happy to discuss how we can help you with project and change management, interim or project staffing assistance, system report creation and dashboarding, and revenue cycle optimization. Contact a member of our team.                                                              

Read this if you are looking to find balance with digital usage at your organization.

The current digital well-being environment

Over the last few decades, there has been a major shift in the use of smartphones, laptops, tablets, and other devices. Technology has become an integral part of people’s private and professional lives and the constant innovations and improvements in technology have made information much more accessible than ever before. Some people are finding themselves to be too reliant on technology, however, and the transition to a technology-driven environment and constant exposure to screens have led to a serious dilemma for employees and employers: finding a healthy work-life balance. 

Studies have consistently shown the detrimental effects of excessive technology use, which include:

• Physical health concerns, such as vision problems, neck strain, and even heart complications due to extended periods of sedentary behavior.
• Mental health concerns, such as increased stress, anxiety, depression, and a general sense of dissatisfaction with life.
• Social isolation and feelings of loneliness, as digital interactions may not fully substitute for meaningful face-to-face connections.
• Disrupted sleep patterns, as the use of technology before bedtime makes it harder to obtain quality sleep and can lead to sleep disorders.
• Reduced engagement and performance in the workplace, potentially impacting productivity and job satisfaction.

What is digital well-being? 

The negative impacts of excessive technology use can prevent employees from maximizing their potential. This has paved the way for digital well-being, which is an emerging concept designed to help manage some of the inherent risks of increased technology use and help employees find an ideal work-life balance. 

Digital well-being is about creating and maintaining a healthy relationship with technology. It is a subjective and individual experience of understanding the optimal balance between the benefits and drawbacks obtained from technology. A common example of how technology can have a negative impact on employees is the overuse of social media during the workday. This can quickly lead to employee disengagement and decrease work performance. Although many workers rely on technology to perform their jobs, digital well-being is about using technology in such a way that helps employees. Objectives for increasing digital well-being include:

• Developing a clear understanding of the advantages and potential risks associated with technology usage.
• Striking a balance between professional commitments and personal life responsibilities. 
• Cultivating and maintaining meaningful connections with coworkers, family members, and friends. 
• Efficiently managing workload and minimizing digital distractions.
• Actively participating in social and community events and activities.

Why is digital well-being important?

With the shift to a technology-driven environment, the ability to concentrate without distraction is becoming increasingly valuable among employers. An individual’s technological dependencies and habits may decrease their ability to focus for prolonged periods of time, especially if they are constantly interrupted by incoming communications and notifications. Technology should help individuals achieve their private and professional goals, rather than distract them or get in the way.

Digital well-being enables employees to be more engaged and productive, as well as maintain healthier lives outside of the workplace. Adopting leading digital well-being practices can help employees focus on their work and cause less exhaustion and distraction. For example, an employee who checks their smartphone four to five times a day will likely be more productive than someone who regularly checks their device every few minutes. This can result in improved individual performance over time and a greater contribution to team and company performance.

Finding balance in the workplace

As remote work gains popularity and flexible work arrangements become the norm, technology can be both helpful and intrusive. Collaboration tools, such as Zoom and Microsoft Teams, can help keep employees digitally connected but can also be distracting for team members being bombarded with communications and requests. Additionally, employees may be tempted (or expected) to answer communications and continue to work after the workday is over. This makes it hard for employees to separate their work life from their private life. But employers can help their workforce find this balance. 

The National Day of Unplugging, celebrated on the first Friday of March, has been followed by many organizations for several years and encourages people to disconnect from technology for 24 hours and engage in activities that promote well-being. 

Best practices for digital well-being

Ultimately, employees are responsible for their digital well-being. Simple changes made consistently over time can make a big impact. Some best practices for individuals to follow include:

• Be mindful of the information and media you consume online. By engaging with reliable sources, fact-checking information, and balancing digital experiences with offline activities, you can increase your digital well-being.
• Focus on positive aspects and achievements of others online. When you avoid negative social comparisons online, you develop healthier relationships and interactions online.
• Understand and manage your digital identity and footprint. Our online habits and activity can shape how others perceive us and can impact our personal and professional lives. This is especially true for social media. By being mindful of the impact our words and actions can have, we can contribute to a more supportive digital community.
• Express yourself and be creative. It is important to engage in creative activities online that promote mental well-being, boost self-esteem, and enable you to explore your passions and talents.
• Address digital clutter. The accumulation of unnecessary and disorganized digital files, emails, and applications can have a negative impact on productivity and stress levels.
• Optimize workspaces. Whether you are in the office or at home, an optimal workspace can improve productivity and reduce distractions. 
• Distinguish between intentional and passive use of technology. Intentional use involves purposeful engagement, while passive use can lead to mindless scrolling and excessive screen time, which can negatively impact your overall well-being.
• Set boundaries and take breaks. Engaging in offline activities, practicing mindfulness, and setting boundaries with technology allows individuals to recharge, reduce stress, and maintain a healthy balance between digital engagement and self-care.
• Develop a healthy pre-sleep routine. Getting sufficient and quality sleep is essential for overall well-being. Excessive use of digital devices, particularly before bedtime, can disrupt sleep patterns and negatively impact physical health.
• Consider a digital detox. Sometimes we just need a break from digital devices and social media platforms. A digital detox is a period when you disconnect from digital devices and technology, typically for a temporary duration, to reduce screen time and digital distractions and promote overall well-being.

To encourage and help workers find a healthy work-life balance, employers should:

• Foster a positive digital culture. Encourage collaboration, enhance employee engagement, and prioritize well-being. This type of culture can promote effective communication, reduce misunderstandings, and enhance productivity.
• Train employees on how to use digital tools and platforms. Being familiar with technology allows your team to adapt to new tools and stay updated in a fast-paced digital environment.
• Help employees stay focused and limit distractions. You should not only focus on training your team on how to use technology, but also provide guidance on how to concentrate on tasks, be more efficient, minimize interruptions, and achieve goals. 
• Educate employees on privacy and security. This can help your employees feel more confident and empowered in their use of technology and can help reduce the risk of cyberattacks, such as data breaches and ransomware attacks.
• Provide ergonomic support and help optimize workspaces. Whether your team members are in the office or at home, it is important to help create workspaces that support proper posture, comfort, and overall well-being. 
• Collaborate and communicate strategically. Collaboration and communication are critical for teams, particularly for hybrid and remote workforces. At the same time, excessive emails and chats can be distracting and lead to disengagement. Too many meetings, particularly virtual meetings, can also lead to physical and mental fatigue. When possible, find ways to meet face-to-face.
• Support employees on their digital journey. You should provide resources to help your team develop healthy digital habits, manage stress levels, avoid burnout, reduce feelings of isolation, and find a healthy work-life balance.
• Develop a sense of connection and community. This can help create a supportive and inclusive environment that allows team members to share common interests, receive support, engage in collaborative activities, and foster a sense of belonging.
• Check in with employees on a regular basis to verify that their digital needs are being met. Managers should ask targeted questions such as: Are you finding it difficult to disconnect from work after hours? Are there tools you feel that are hindering your productivity or well-being? Do you feel a sense of fulfillment, satisfaction, and purpose in your work?
• Encourage breaks and physical activity throughout the workday. By decreasing the amount of screen time and allowing the brain to rest and recharge throughout the workday, team members can reduce eye strain, fatigue, and other physical discomforts, improve productivity, reduce stress levels, elevate mood, and enhance creativity. Your organization may consider implementing activity challenges to promote physical activity and encourage healthy behaviors.  
• Encourage employees to disconnect. Managers should set clear expectations for when employees need to be available and advise them only to contact one another after hours with urgent matters. Additionally, when possible, employees should have the ability to turn off notifications on personal devices after workday hours.

Conclusion

It is important for organizations to recognize the impact of technology on employee health and happiness. In today's current environment, technology is an essential part of daily operations, and its overuse can quickly lead to burnout, stress, and decreased productivity. 

Being proactive about employee digital well-being leads to a more supportive work environment that benefits both employees and the organization. This can lead to higher productivity, increased job satisfaction, and reduced turnover rates. Additionally, it sends a clear message to current and potential employees that the organization cares about their well-being, which can help to attract and retain top talent. 

Digital well-being resources

If you would like more information about digital well-being or have questions about your specific situation, please contact our Well-being Consulting team. We’re here to help.

Read this if you are an organization that was operating during the pandemic. 

By now, most of you have encountered advertisements from third-party vendors who are promoting their Employee Retention Credit (ERC) service. These advertisements often come with the promise of significant credits if you kept employees on payroll during the pandemic and complete a short survey. The impact of these advertisements is twofold; first, it misleads businesses and organizations into incorrectly claiming the credit, and second, it deters other organizations, who are eligible for the credit, from applying for the credit because it seems too good to be true.

The ERC is a valuable credit for organizations that meet the eligibility requirements

The fact is—for businesses and organizations that are truly eligible—the ERC can provide a substantial amount of money designed to offset some of the hardships experienced as a result of the pandemic, which is echoed by the comment from acting IRS Commissioner Doug O’Donnell who said, “While this is a legitimate credit that provides a financial lifeline to millions of businesses, there continue to be promoters who aggressively mislead people and businesses into thinking they can claim these credits.”

At BerryDunn, we are in the unique position of seeing the situation from both sides—the consulting side and the auditing side.  We have partnered with many consulting clients to help them gather and evaluate the documentation needed to determine eligibility, calculate their credit, and prepare the forms necessary to claim the credit. For these clients, the ERC has provided meaningful cash to offset the impact the pandemic had on operations.

On the other hand, we have had many conversations with employers who do not appear to meet the eligibility requirements but continue to receive constant marketing materials from third-party vendors. In addition, our audit team has been in the unfortunate position of having difficult discussions with businesses and organizations who have used a third-party vendor who took aggressive and misleading positions to claim the ERC.

These are some of the red flags we have seen when auditing the ERC for businesses and organizations who have used one of these third-party vendors:

Exorbitant fees charged by ERC third-parties

Since the ERC is often viewed as “found money,” businesses and organizations have been willing to pay exorbitant fees that can range from 10% to 15% (or more) of the calculated credit, which could end up being $1M or more in some cases. Most reputable firms will charge a flat fee based on hours worked or number of employees or a fee based on the credit received, not expected, and will refund businesses for any monies that are taken back due to audit. These types of arrangements will likely end up charging lower fees than those arrangements charging a percentage of the calculated credit, whether claimed or not.

Reliance on Federal Orders to prove ERC eligibility

CDC and OSHA guidelines by themselves issued during the pandemic generally do not constitute a valid government order for the purposes of the ERC. However, most third-party vendors are relying on these federal guidelines to determine eligibility. It does not appear these guidelines will be viewed favorably under an IRS audit or a financial statement audit. As a result, allowances/reserves may be required for financial statements purposes and the IRS may disallow the credit.

Complete reliance on an ERC third-party vendor

Management is responsible for filing the necessary forms with the IRS to claim the credit, not the third-party vendor. Therefore, management should understand the basics of the credit and how it could apply to their business or organization before signing a contract.

Lack of documentation in determining ERC eligibility

Determining eligibility for the ERC can be complicated, especially if you are relying on government orders. This full or partial shutdown analysis involves analyzing various state orders and how they impacted your operations and/or gross receipts. Your financial statement auditors, as well as the IRS, will want to see detailed documentation to support your eligibility for the ERC, not simply a listing of every state or local order issued during the pandemic with no clear correlation of how they impacted your operations. If the third-party vendor is determining your ERC eligibility and calculating your credit based on a small amount of financial information or documentation from you, chances are, it will not stand up under an audit.

The bottom line: Do your due diligence and be aware of overly aggressive third-party vendors, because you may end up paying an exorbitant fee for the service, and your ERC claim may not stand up to an IRS audit, leaving you in a position to return the credit to the IRS while still owing the full agreed upon fee to the third-party vendor.

Choosing a reputable third-party ERC vendor

The good news, though, is that there are many reputable vendors out there, who will be good partners to you in determining eligibility for the ERC and ensuring that your claim will stand up to an audit. As with any third party, you will need to do some due diligence. Some simple questions to ask are:

• How long has the company been in business?
• Do they have a good reputation?
• Do they offer other services?
• What is their stance on the ERC credit: aggressive or conservative?
• Do they charge a flat fee or a percentage?
• If your credit were to be audited in three to five years, will the vendor still be around to provide audit support?

If you believe your company or organization is eligible to claim the ERC, it is in your best interest to hire a reputable firm to guide your business or organization through the process. Our experts would welcome the opportunity to consult with you, whether you are just beginning the process, or have hit some bumps in the road. Contact our team.

Read these other articles for more ERC education.

Too good to be true? IRS warns employers of ERC scams

Employee benefit plan updates: The Employee Retention Credit and student loan repayment programs

Do you know what would happen to your company if your CEO suddenly had to resign immediately for personal reasons? Or got seriously ill? Or worse, died? These scenarios, while rare, do happen, and many companies are not prepared. In fact, 45% of US companies do not have a contingency plan for CEO succession, according to a 2020 Harvard Business Review study.  

Do you have a plan for CEO succession? As a business owner, you may have an exit strategy in place for your company, but do you have a plan to bridge the leadership gap for you and each member of your leadership team? Does the plan include the kind of crises listed above? What would you do if your next-in-line left suddenly? 

Whether yours is a family-owned business, a company of equity partners, or a private company with a governing body, here are things to consider when you’re faced with a situation where your CEO has abruptly departed or has decided to step down.  

1. Get a plan in place. First, assess the situation and figure out your priorities. If there is already a plan for these types of circumstances, evaluate how much of it is applicable to this particular circumstance. For example, if the plan is for the stepping down or announced retirement of your CEO, but some other catastrophic event occurs, you may need to adjust key components and focus on immediate messaging rather than future positioning. If there is no plan, assign a small team to create one immediately. 

Make sure management, team leaders, and employees are aware and informed of your progress; this will help keep you organized and streamline communications. Management needs to take the lead and select a point person to document the process. Management also needs to take the lead in demeanor. Model your actions so employees can see the situation is being handled with care. Once a strategy is identified based on your priorities, draft a plan that includes what happens now, in the immediate future, and beyond. Include timetables so people know when decisions will be made.  

2. Communicate clearly, and often. In times of uncertainty, your employees will need as much specific information as you can give them. Knowing when they will hear from you, even if it is “we have nothing new to report” builds trust and keeps them vested and involved. By letting them know what your plan is, when they’ll receive another update, what to tell clients, and even what specifics you can give them (e.g., who will take over which CEO responsibility and for how long), you make them feel that they are important stakeholders, and not just bystanders. Stakeholders are more likely to be strong supporters during and after any transition that needs to take place. 

3. Pull in professional help. Depending on your resources, we recommend bringing in a professional to help you handle the situation at hand. At the very least, call in an objective opinion. You’ll need someone who can help you make decisions when emotions are running high. Bringing someone on board that can help you decipher what you have to work with and what your legal and other obligations may be, help rally your team, deal with the media, and manage emotions can be invaluable during a challenging time. Even if it’s temporary. 

4. Develop a timeline. Figure out how much time you have for the transition. For example, if your CEO is ill and will be stepping down in six months, you have time to update any existing exit strategy or succession plan you have in place. Things to include in the timeline: 

• Who is taking over what responsibilities? 
• How and what will be communicated to your company and stakeholders? 
• How and what will be communicated to the market? 
• How will you bring in the CEO's replacement, while helping the current CEO transition out of the organization? 

If you are in a crisis situation (e.g., your CEO has been suddenly forced out or asked to leave without a public explanation), you won’t have the luxury of time.  

Find out what other arrangements have been made in the past and update them as needed. Work with your PR firm to help with your change management and do the right things for all involved to salvage the company’s reputation. When handled correctly, crises don’t have to have a lasting negative impact on your business.   

5. Manage change effectively. When you’re under the gun to quickly make significant changes at the top, you need to understand how the changes may affect various parts of your company. While instinct may tell you to focus externally, don’t neglect your employees. Be as transparent as you possibly can be, present an action plan, ask for support, and get them involved in keeping the environment positive. Whether you bring in professionals or not, make sure you allow for questions, feedback, and even discord if challenging information is being revealed.  

6. Handle the media. Crisis rule #1 is making it clear who can, and who cannot, speak to the media. Assign a point person for all external inquiries and instruct employees to refer all reporter requests for comment to that point person. You absolutely do not want employees leaking sensitive information to the media. 
 
With your employees on board with the change management action plan, you can now focus on external communications and how you will present what is happening to the media. This is not completely under your control. Technology and social media changed the game in terms of speed and access to information to the public and transparency when it comes to corporate leadership. Present a message to the media quickly that coincides with your values as a company. If you are dealing with a scandal where public trust is involved and your CEO is stepping down, handling this effectively will take tact and most likely a team of professionals to help. 

Exit strategies are planning tools. Uncontrollable events occur and we don’t always get to follow our plan as we would have liked. Your organization can still be prepared and know what to do in an emergency situation or sudden crisis.  Executives move out of their roles every day, but how companies respond to these changes is reflective of the strategy in place to handle unexpected situations. Be as prepared as possible. Own your challenges. Stay accountable. 

BerryDunn can help whether you need extra assistance in your office during peak times or interim leadership support during periods of transition. We offer the expertise of a fully staffed accounting department for short-term assignments or long-term engagements―so you can focus on your business. Meet our interim assistance experts.

Read this if you participate in onboarding healthcare providers. 

The last several years have certainly been challenging for healthcare. Fueled by the COVID pandemic, increased provider burnout is a huge issue that has organizations grasping to keep staffing levels high enough to provide exceptional patient care. Physician turnover (per physician) has been estimated to cost an organization between $400,000 and $1,000,000 when factoring in recruiting costs and lost patient billing revenue. For smaller organizations, that can be a major challenge. 

The US Department of Labor Statistics estimates that by 2030 the healthcare industry will grow more than 16%, adding over 2.6 million new jobs. With 5% of physicians turning over each year (this number doubles when including physician assistants and physical therapists) and 61% reporting burnout, organizations should take steps now to minimize attrition and ensure a stable clinical workforce. 

Provider onboarding as a retention strategy

Provider onboarding is a window into an organization’s culture and is the foundation of the provider experience. During this period, action and inaction, both real or perceived, will set a new hire’s impressions of the organization. A positive experience can ensure early buy-in from new providers, helping employers improve retention rates and provider satisfaction. 

For many organizations, onboarding and orientation are the same. However, there are differences. Orientation is a one-time event for tasks (i.e., completing an I-9 form, new-hire paperwork, discussing benefits). Onboarding is an experience that begins once a provider has accepted the position and will last at least 90 to 120 days. The provider will have contact with human resources, IT, the medical staff office, and finance/revenue cycle departments to gather much of the same data (e.g., licensure, CV, NPI, and other demographic information).

A well-organized and coordinated organization can reduce the number of times a provider is asked for the same information or documents. Clear communication and centralized points of contact and processes are critical to a smooth process. To help organize onboarding, you can download our Provider Onboarding Checklist.

Ensuring you have all the information and documents your organization will need from the provider for privileging, third-party payer enrollments, HR, and IT has additional benefits beyond provider experience. Preparing new providers to participate on a payer panel linked to the organization can be an exceptionally lengthy process, often exceeding 90 to 120 business days. Additionally, if your organization participates with a large volume of managed Medicare and Medicaid payers, gathering the information and beginning the process early through an efficient onboarding can ensure you decrease write-offs of billable services to the dreaded ‘provider not credentialed’ denial code.

Provider onboarding and timely, quality patient care

Equally important is the connection to delivering timely and quality patient care, as the third-party payer process directly impacts these activities. An unenrolled provider lacks the ability to order, prescribe, and refer. This necessitates additional touches, resulting in breakdowns in the workflow that can lead to unnecessary expense and provider dissatisfaction. The provider enrollment process must be initiated early, and frequent communication with all involved parties can alleviate any issues. 

Organizations should offer providers robust revenue cycle-related clinical systems training as part of the onboarding process and create a mechanism to identify potential errors that may lead to write-offs and compliance risks. Provider entry errors can result in a claim ending up in a work queue, never to be identified, submitted, or paid. You can mitigate revenue loss by monitoring entry errors and providing additional training. Wasteful workforce expenditures are created through revenue cycle teams chasing information to be corrected, causing rework. Education for providers and everyone supporting them in operations will also go a long way toward reducing errors, increasing satisfaction, and minimizing barriers to care and collection challenges. 

If you would like more information or have questions about your specific situation, please reach out to our credentialing consulting team. We’re here to help. 
 

Read this if you work for a healthcare organization that serves uninsured or self-pay patients.

The No Surprises Act was passed in 2020 as part of a COVID relief package, with the goal of reducing surprise bills for patients who received medical or surgical services. One part of the act requires healthcare facilities and providers to give Good Faith Estimates (GFEs) to uninsured and self-pay patients starting on January 1, 2022. Read on for frequently asked questions about this topic, an update for 2023, and resources where you can find more information.

Frequently asked questions about good faith estimates for healthcare

What is a good faith estimate?

A Good Faith Estimate (GFE) is a document provided to a patient that details the expected charges for healthcare services provided. It is not a bill.

Who needs to provide GFEs, and to whom?

At this time, GFEs need to be provided to uninsured and self-pay patients. 

The following healthcare facilities must comply:

• Federally Qualified Health Centers (FQHCs)
• FQHC Look-Alikes
• Tribal/Urban Indian Health Centers
• Rural Health Clinics (RHCs)
• Hospitals
• Hospital outpatient departments
• Critical access hospitals
• Title X Family Planning Clinics
• Health care providers who serve uninsured and self-pay patients

How should information about the GFE process be communicated to uninsured and self-pay individuals?

Information about the availability of GFEs for uninsured or self-pay individuals must be:

• Written in a clear and understandable manner and prominently displayed:
• On the facility’s website and easily searchable from a public search engine
• In the office (such as in the patient waiting room), and
• Onsite where scheduling or questions about the cost of items or services occur, such as at the registration or check-out areas
• Explained verbally when scheduling an item or service or when questions about the cost of items or services occur
• Made available in accessible formats, and in the languages spoken by individuals considering or scheduling items or services

How does the US Department of Health and Human Services (HHS) define uninsured and self-pay individuals?

HHS has a two-fold definition:

• Individuals who have no health insurance coverage
• Individuals who do have health insurance coverage, but do not want to have a claim submitted to their insurer

Both of these groups of individuals must receive a GFE.

What content is required in a GFE?

A GFE must include the following:

Patient information

• The patient’s name and date of birth

Services estimated

• A description of the primary item or service in clear and understandable language and, if applicable, the date the primary item or service is scheduled
• A list of items or services reasonably expected to be furnished for the primary item or service

Information about services, providers, and estimated charges

• Applicable diagnosis codes, expected service codes, and expected charges associated with each listed item or service
• The name, National Provider Identifier, and Tax Identification Number of each provider or facility represented in the GFE, and the State and office of the facility’s location where the items are services are expected to be provided
• Lists of items or services that the provider or facility anticipates will require separate scheduling and that are expected to occur before or following the expected period of care for the primary item or service. (A disclaimer should state that separate GFEs will be issued upon scheduling or upon request of the listed items or services.)

Disclaimers

• A disclaimer that there may be additional items or services that the provider or facility recommends as part of the course of care that must be scheduled or requested separately and are not included in the GFE
• A disclaimer that the information provided in the GFE is only an estimate and that actual items, services, or charges may differ from the GFE
• A disclaimer that the individual has a right to initiate the patient-provider dispute resolution process if the actual billed charges are substantially in excess of the expected charges included in the GFE.
• “Substantially in excess” is defined as at least $400 more than the total amount of expected charges.
• This disclaimer must include instructions about where an uninsured or self-pay individual can find information about how to initiate the patient-provider dispute resolution process and state that the initiation of the patient-provider dispute resolution process will not adversely affect the quality of health care services that are furnished.
• HHS strongly encourages providers and facilities to include an email address and telephone number for someone within the provider’s or facility’s office that has the authority to represent the provider or facility in a billing dispute.
• A disclaimer that a GFE is not a contract and does not require the uninsured or self-pay individual to obtain the items or services identified in the GFE.

HHS encourages sliding fee discount providers and facilities to include information about the provider’s or facility’s sliding fee schedule and any other financial protections that it offers. Sliding fee discount providers and facilities have flexibility to determine how best to demonstrate the expected charges associated with each listed item or service, and to determine what additional information to include, if any.

What are the required methods for providing a GFE?

A GFE must be provided in written form either on paper or electronically, based on the individual’s requested method of delivery and within the required time frames. GFEs that are provided electronically must be provided in a manner that the individual can both save and print. A GFE must be written using clear and understandable language that can be understood by the average uninsured or self-pay individual.

If the individual requests a GFE in a method other than on paper or electronically (such as by telephone or verbally in person), the provider or facility may verbally inform the individual of the information contained in the GFE. However, the provider or facility must also issue the GFE in written form.

What is the timeline for providing a GFE?

When providing a GFE to an uninsured or self-pay patient, the following time frames must be followed.

Please note, when a GFE is requested by an uninsured or self-pay patient, a GFE must be provided not later than 3 business days after the date of the request.

How long should a provider or facility retain a copy of GFEs?

A GFE is considered part of the patient’s medical record and must be maintained in the same manner. At the request of an uninsured or self-pay individual, the provider or facility must provide a copy of any previously issued GFE within the last six years.

Update for 2023

• As of the start of 2023, all of the preceding requirements remain in place.
• As of January 1, 2023, HHS has paused enforcement on the next phase of GFE implementation

The next phase of GFE implementation, which began on January 1, 2023, requires that GFEs for uninsured and self-pay patients include expected charges from co-providers or co-facilities that are part of an episode of care for a patient coordinated by a provider or facility. However, on December 2, 2022, HHS paused its enforcement of this requirement based on comments it received during the rulemaking process indicating that compliance with this provision was likely not possible by January 1, 2023.

HHS is extending enforcement discretion, pending future rulemaking, for situations where GFEs for uninsured or self-pay individuals do not include expected charges from co-providers or co-facilities. We will provide an update when HHS issues any communication about changes to GFE-related enforcement.

Helpful resources for FQHC, RHCs, and other healthcare facilities

• Code of Federal Regulations: Requirements for provision of good faith estimates of expected charges for uninsured (or self-pay) individuals.
• Code of Federal Regulations: Requirements for the patient-provider dispute resolution process.
• CMS Good Faith Estimates FAQ December 2021 (PDF)
• CMS Good Faith Estimates FAQ April 2022 (PDF)
• CMS Good Faith Estimates FAQ December 2, 2022 (PDF)
• CMS Good Faith Estimates FAQ December 27, 2022 (PDF)

If you have questions about the information provided in this article or are interested in an external review of your healthcare facility’s compliance with current GFE requirements, please contact Robyn Hoffmann or Mary Dowes.