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Home My WebLink About04/05/2021 - Regular Minutes - City Council - Audit CommitteeEmergency Medical ServicesBilling and Collections AuditApril 5, 2021Audit Committee Meeting $859.84 balance bill charged to patientInstructs patientsto contact vendorServicechargedAmount paid by commercial insurance Overview of Audit FindingsThe EMS fee setting process could be improvedA few potential billing discrepanciesRisk of improper remittancesNon‐compliance with some contractual stipulationsBackgroundBilling DiscrepanciesProper Remittances RiskEMS Fee ProcessContract Non‐complianceBackground EMSServiceCityLimitsPrior to 10/1/19 Res. No. 09‐26‐19‐2dBase Fee Fee/mile Base Fee Fee/mileBLS inside $650 $15 $1,200 $19BLS outside $650 $18 $1,200 $19ALS1 inside $850 $15 $1,400 $19ALS1 outside $850 $18 $1,400 $19ALS2 inside $950 $15 $1,650 $19ALS2 outside $950 $18 $1,650 $19SCT $1,700 $19Non‐Res. EMS $100 $ 250Oxygen $ 85 $ 130Supplies (BLS) $150 $ 200Supplies (ALS) $300 $ 400City of College Station EMS Fee ScheduleBackgroundBilling DiscrepanciesProper Remittances RiskEMS Fee ProcessContract Non‐complianceEMS Fee Process Methodology Used to Determine EMS FeesServiceCurrent FeeProposed FeePercent increaseAvg. of Agencies*Highest Agencies*ALS 850 1,400 65% 1,357 1,800 Santa FeALS‐2 950 1,650 74% 1,617 1,800 Santa FeBLS 650 1,200 85% 1,198 1,800 Santa FeALS Disposable 300 400 33% 369 450 Santa FeBLS Disposable 150 200 33% 174 250 Santa FeOxygen 85 130 53% 131 150 TravisSCT 950 1,700 79% 1,704 1,850 FreeportTNT 100 250 150% 225 400 FreeportGround mileage 18 19 6% 17 21 Freeport* The agencies examined were Santa Fe, Bellaire, Bulverde, Travis County, Freeport, and Friendswood BackgroundBilling DiscrepanciesProper Remittances RiskEMS Fee ProcessContract Non‐complianceEMS Fee Process Overbilling Billing RiskHow customers can catch it:•Compare bill to approved fee schedule•EMS rates must be effectively advertised•Citizen must be familiar with EMS care provided•Request City compare bill to patient report•Bill instructs patients to contact the provider•Contract requires vendor to report complaintsHow:Up charge the service, supplies, or mileageHow the City can catch it:•Reconcile billings to patient care reports•Require EMTs to record service provided•Hire expert to perform reconciliation•Capture customer complaints•Require and verify vendor is reporting customer complaints to the City•Method for customer to contact City directlyBackgroundBilling DiscrepanciesProper Remittances RiskEMS Fee ProcessContract Non‐complianceBilling Discrepancies EMS Billing to City Approved Fee Schedule Reconciliation ResultsCategory ALS ALS2 BLS Non‐Res Totals % of TotalBase Fee, Mileage,Supplies, Oxygen309 54 65 0 428 3.0%Base Fee, Mileage, Supplies 3,077 46 1,239 0 4,362 30.9%Base Fee, Mileage, Oxygen 4 0 1 0 5 0.0%Base Fee, Mileage 6,396 190 2,260 0 8,846 62.8%Base Fee 0 0 130 0 130 0.9%Non‐Resident EMS 0 0 0 209 209 1.5%Exceptions 77 2 34 1 114 0.8%Total 9,863 292 3,729 210 14,094 100.0%% of Total 70% 2% 26% 1% 100% NABackgroundBilling DiscrepanciesProper Remittances RiskEMS Fee ProcessContract Non‐complianceBilling Discrepancies Under Remitting RiskHow to mitigate risk:•Reconcile billings to patient care reports•Segregation of functions/duties•SSAE audits•Independently evaluates the vendor’s system and organization controlsHow:Record and remit less than actually collected – i.e., understate amount collected oroverstate contractual allowances or write‐offsBackgroundBilling DiscrepanciesProper Remittances RiskEMS Fee ProcessContract Non‐complianceIndicators of Risk:•Records state that about 2/3 of billings are not charged supplies, BLS has roughly the same rate of non supply charges as ALS and ALS2•$16 million billed and $6 million collected from FY18 – FY20; some discrepancies in contractual allowances were also identifiedProper Remittances Risk Contract Performance & Non‐ComplianceCriteria for Contract Performance: – Emergicon’s own best practice materials•“billing companies should provide their clients with an annual recommendation to their EMS fee schedule to ensure that fees capture allowable Medicare amounts and maximize commercial insurance payments.”•“stretching EMS fee structure to maximum levels is a shortsighted approach that leads to increased denial rates and political problems with residents who disagree with higher-than-market fees for ambulance transport.” •“a billing company should incrementally increase collections over time.”BackgroundBilling DiscrepanciesProper Remittances RiskEMS Fee ProcessContract Non‐complianceContract Performance Results:•The collection rate in fiscal years 2018, 2019, and 2020 was 41%, 41%, and 29%, respectively. •BLS, ALS, and ALS2 fees increased by 85%, 65%, and 74% respectively. Although these fee increases resulted in a 59% increase in charges, revenue only increased by 14%. Most of this increase is due to citizens paying the bill balance their insurance provider did not cover.Contract Compliance Results:•Charged incorrect fee on some accounts resulting in potential overcharges to the City of between $25,000 and $33,000. Recommendations1. Develop processes to better monitor the performance of the contract2. Track the services provided to facilitate periodic reconciliations 3. Require SSAE 18 audits conducted by an independent CPA firm4. Develop procedures to ensure webpages state current EMS fees5. Consider segregating billing and collection functions6. Improve the EMS fee setting process and methodology Special Report: Fire Department Culture and OperationsMarch 2021 Report Limitations1. Does not meet the standards of an audit= No audit recommendations2. Observations occurred in Sept 2019 & focus group concluded in Mar 2020= Concerns identified during these time periods may have been addressed3. Suggestions are the expressed opinions of the firefighters who offered them= Do not represent the opinions of all firefighters Report Sections1. Leadership/Administration2. Cronyism/Nepotism3. Department Division4. Compensation5. Turnover6. Leave/Overtime7. Paramedic Shortage8. Apparatus Staffing9. Physical Health10.Workload Efficiency11.Auto Aid with Bryan12.Recruiting13.Promotion14.Training/Certifications15.Special Programs Report Format ExampleLeadership/AdministrationFirefighter Concerns: Many factors were brought to the auditors’ attention regarding poor leadership within CSFD such as inconsistent communication, insufficient pay and benefits, ineffective recruitment and retention…….Fire Suggestion(s): Lack of trust was identified as the key cause of discount between firefighters and CSFD leadership. Many felt a change in leadership was needed. Some referenced…….Auditor Comments: We did not observe any fire administration personnel visiting fire stations. Overall, we found that firefighters tend to favor…….Management Response: …….