All Revenue Cycle employees were instructed never to insist that patients pay residual or priorbalances or suggest to patients that they would not receive treatment unlessthey paid. Training materials and employee scripts for both Accretive Healthand Fairview employees emphasized this in red, bolded, capitalized type:
PLEASE READ: NOT ONLY ARE PATIENTS NEVER TO BE DENIED SERVICE FOR NON-PAYMENT, THEY ARE NEVER TO BE GIVEN THE IMPRESSION THAT SERVICE WOULD BE DENIED FOR NON-PAYMENT
At Fairview, emergency room patients were given a medical screening examination by a clinician and any necessary stabilizing treatment. While emergency room patients went through the same registration process as scheduled patients, this process occurred
the patient had been screened and, if necessary, stabilized.
Revenue Cycle employees were permitted to
This practice is also consistent with the “recommended practices” advocated by the HFMA. HFMA places great emphasis on “early, transparent financial communications” with patients so that they understand
treatmenttheir possible out-of-pocket costs as well as any available paymentalternatives. HFMA advises that “[i]f urgent care needs prevent these stepsfrom being taken before services are delivered, providers complete these steps
11speak with emergency room patients as dictated by the clinici ans and thepatient’s condition, but only during “down times” (such as when the patient was waiting for test results or otherwise was not being treated by clinicians), andonly after the patient had been screened and stabilized. The main focus was toverify the patient’s insurance and to obtain any necessary authorizations which may be time sensitive. After screening and stabilization, and as a part of the registration process,emergency room patients, like scheduled patients, were provided estimates regarding their cost of care, counseling regarding available payment alternatives, and an opportunity to pay their own calculated portion of the balance if they so chose. Accretive Health and Fairview’s policy, however, was that an emergency room patient’s treatment was