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CMS Urged to Lighten Rev Cycle Staff Burden

Analysis  |  By Amanda Norris  
   September 28, 2022

Hospital groups are asking CMS to avoid added advanced explanation of benefits (AEOB) burdens.

The American Hospital Association, American Medical Association, and Medical Group Management Association are urging CMS not to include a convening framework when implementing the AEOB and insured good faith estimate (GFE) provisions under the No Surprises Act.

For background, the convener requirement asks staff to create charge estimates for patients that cover not only their own services but those of downstream providers, creating an AEOB.

CMS is being asked that it reject any standard process that would require billing providers to consolidate cost data into a single GFE prior to submission to an insurer for the creation of an AEOB, “as it is neither practical nor in the patients’ best interests,” the groups said.

Instead, the groups say CMS should allow each billing provider to submit their own GFE to the health plan to create an AEOB. 

“In addition to the inefficiencies with creating a new process discussed above, we also are concerned about the volume of comprehensive GFEs that would need to be created if the convening provider/co-provider framework were to be applied to all patients,” the letter said.

As revenue cycle leaders are aware, and as the groups echo in the letter, the creation of comprehensive GFEs for uninsured patients are burdensome and the process requires a significant amount of administrative time.

“While this process may ultimately be tenable for the uninsured patient population (if technical solutions can be successfully developed), it will inevitably add burden on providers, who will need to navigate an entirely new process prior to care,” the groups add.

In the letter the groups cite the 2020 Census data that shows approximately 8.6% of Americans are uninsured. Conversely, over 61% of Americans are covered under commercial health insurance, the groups said, whose care would be subject to the AEOB requirements.

“As a result, the volume of additional administrative work if the convening provider/co-provider were to be applied to the insured population would be impractical and unsustainable. This would likely result in care delays as providers would need substantial time to complete this process in between scheduling and providing care,” the groups said.

The added administrative burden would drive up costs for organizations as they would need to hire more revenue cycle staff during a time of widespread labor shortages.

Amanda Norris is the Revenue Cycle Editor for HealthLeaders.


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