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Chapter 46., Section 13. Pursuing Third Party Funding — Main Section | Community Tool Box

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mloewenstein Thu, 12/13/2012 - 11:58

A community health and family-support center provides several types of services. Some preventive and behavioral health services are billed to health plans or public insurance programs when they meet applicable coverage and billing requirements. A school district pays for certain educational evaluations under a separate agreement. Other community activities are supported through grants, public programs, charitable contributions, or institutional funding.

Many participants pay little or nothing directly for covered services, but that does not mean every service is "free" or that every activity can be billed to an insurer.

The center uses several financing sources because no single payment method supports all of its work.

Third-party reimbursement can be an important part of that financial strategy, but it brings substantial requirements involving enrollment, credentialing, contracts, eligibility verification, coding, documentation, privacy, billing, prior authorization, claims management, audits, and compliance.

What is third-party payment?

Third-party payment or third-party reimbursement occurs when an entity other than the person receiving the service pays some or all of the allowable cost.

Depending on the service and jurisdiction, third-party payers may include:

  • Commercial health insurance plans
  • Medicare
  • Medicaid
  • Children's Health Insurance Program (CHIP)
  • Medicare Advantage or Medicaid managed care organizations
  • School districts or educational agencies
  • State, tribal, territorial, or local agencies
  • Employer-sponsored plans
  • Workers' compensation or other specialized programs
  • Other organizations contractually responsible for eligible services

Third-party reimbursement is not one uniform system.

A payer may reimburse through:

  • A fee schedule
  • A negotiated contracted rate
  • A prospective-payment methodology
  • Bundled payment
  • Capitation
  • Value-based arrangements
  • Case rates
  • Another payment methodology

The amount ultimately paid may also depend on coverage, eligibility, deductibles, copayments, coinsurance, network status, prior authorization, coding, documentation, medical necessity, contractual adjustments, and other rules.

Before relying on third-party reimbursement, understand both the service-delivery requirements and the revenue-cycle requirements associated with each payer.

What are the potential advantages of third-party reimbursement?

Greater access to services

Insurance, public programs, school funding, and other third-party financing may reduce the amount participants must pay directly.

This can make services more accessible to people who might otherwise face significant financial barriers.

Coverage alone does not eliminate all barriers. Deductibles, copayments, network limitations, transportation, language, disability access, eligibility, documentation requirements, and other factors may still affect access.

A recurring source of earned program revenue

Reimbursement can create revenue tied to actual service delivery rather than depending entirely on grants or fundraising.

That may provide a useful recurring resource when:

  • A substantial portion of participants have relevant coverage
  • Services are eligible for reimbursement
  • Reimbursement rates reasonably support the cost of providing the services
  • Claims can be submitted accurately and efficiently

Do not assume reimbursement equals full cost recovery.

Compare payment rates with:

  • Staff compensation and benefits
  • Clinical supervision
  • Facilities
  • Technology
  • Billing
  • Credentialing
  • Compliance
  • Documentation
  • Insurance
  • Administrative and indirect costs

Opportunities to strengthen organizational systems

Preparing for third-party billing may lead an organization to strengthen:

  • Clinical documentation
  • Financial controls
  • Data systems
  • Quality assurance
  • Staff credentialing
  • Privacy and security
  • Billing and collections
  • Accessibility

These improvements can benefit the organization even beyond the payer relationship.

Integration into broader service systems

Participation in health plans, public programs, educational systems, or other reimbursement networks may strengthen referral relationships and coordination with other providers.

Enrollment or network participation should not, however, be described as proof that a program is effective or superior. It demonstrates that specified participation requirements have been met.

What are the potential disadvantages and risks?

Administrative burden

Third-party reimbursement can require substantial work involving:

  • Enrollment
  • Credentialing
  • Contracting
  • Eligibility verification
  • Prior authorization
  • Clinical documentation
  • Coding
  • Claims submission
  • Payment posting
  • Denial management
  • Appeals
  • Reporting
  • Audits and reviews

Include these costs when determining whether a reimbursement arrangement is financially worthwhile.

Payment is not guaranteed

Providing a service does not guarantee that a claim will be paid.

Claims may be denied, reduced, delayed, or later recouped because of:

  • Eligibility problems
  • Coverage exclusions
  • Missing authorization
  • Incorrect coding
  • Insufficient documentation
  • Lack of medical necessity under the payer's rules
  • Provider-enrollment problems
  • Timely-filing limits
  • Coordination-of-benefits issues
  • Post-payment review

Plan for accounts receivable and claim delays rather than assuming reimbursement will arrive immediately after service delivery.

Cash-flow risk

Third-party billing can create a significant gap between when the organization provides a service and when it receives payment.

Monitor:

  • Days in accounts receivable
  • Denial rates
  • Collection rates
  • Aging claims
  • Payer-specific payment delays
  • Overpayment liabilities

Maintain enough working capital or reserves to manage predictable delays.

Risk of mission drift

Organizations may begin prioritizing services because they are reimbursable rather than because they best address community priorities.

Regularly ask:

  • Are we changing services primarily because a payer will reimburse them?
  • Are people without coverage receiving meaningfully different access?
  • Are payer documentation requirements affecting how staff spend their time?
  • Are reimbursement incentives consistent with evidence, ethics, and participant needs?

Access inequities

An organization that depends heavily on reimbursement may have financial incentives to prioritize people whose services can be billed.

Develop an explicit strategy for people who are:

  • Uninsured
  • Underinsured
  • Out of network
  • Ineligible for a particular benefit
  • Unable to afford required cost sharing

Depending on the organization, approaches may include grants, public funding, sliding-scale policies, financial assistance, charity care, contracts, or partnerships.

Compliance and audit risk

Reimbursement creates obligations to bill accurately and retain documentation supporting the services claimed.

Improper billing may result in:

  • Claim denial
  • Repayment
  • Corrective action
  • Payment suspension
  • Loss of billing privileges
  • Other administrative, civil, or legal consequences

Build compliance into the program before billing begins.

What services can receive third-party reimbursement?

There is no universal list.

Coverage depends on:

  • The payer
  • The participant's specific plan or program
  • The service
  • Diagnosis or eligibility criteria where applicable
  • Provider type
  • Setting
  • State law
  • Network status
  • Authorization requirements
  • Applicable coverage policy

Potentially reimbursable categories may include:

  • Medical and preventive services
  • Behavioral and mental health services
  • Substance use disorder treatment
  • Physical, occupational, and speech therapy
  • Home and community-based services
  • Certain adult day services
  • Home health services
  • Diagnostic and laboratory services
  • Psychological and neuropsychological assessment
  • Certain educational or developmental evaluations
  • Certain reproductive, preventive, nutrition, or chronic-disease services
  • Other services specifically covered by the payer

Never assume that a service is reimbursable simply because it is beneficial, clinically appropriate, or covered by another payer.

Testing and assessment

Diagnostic testing and assessment should be described more carefully than as the production of a single score.

Depending on the service, an assessment may include:

  • Standardized testing
  • Clinical interview
  • Medical or educational history
  • Behavioral observation
  • Information from caregivers, teachers, or other relevant people when appropriate
  • Functional assessment
  • Integration and interpretation of several information sources

Tests have limitations and should be selected, administered, interpreted, and documented by appropriately qualified professionals.

Results should be interpreted in context rather than treated as perfectly objective measurements independent of health, language, disability, culture, environment, or testing conditions.

Provider and staff requirements

Third-party payers often establish requirements concerning who may provide, supervise, order, refer, certify, or bill for a service.

Requirements may depend on:

  • Profession
  • Licensure
  • Certification
  • Education
  • Experience
  • Scope of practice
  • Supervision
  • Payer enrollment
  • Network credentialing
  • Service type

Do not assume that one payer's credentialing rules apply to another.

Behavioral and mental health services

Depending on the payer and service, eligible professionals may include:

  • Psychiatrists
  • Psychologists
  • Clinical social workers
  • Marriage and family therapists
  • Mental health or professional counselors
  • Psychiatric or other qualified advanced-practice clinicians
  • Other professionals recognized by the applicable payer and state law

Medicare, for example, now allows qualified marriage and family therapists and mental health counselors to enroll independently and bill for covered mental-health services.

Do not use outdated assumptions that most psychotherapy reimbursement requires doctoral-level clinicians.

Mental health conditions should also not be described as simply "chemical." Diagnosis and treatment may involve biological, psychological, developmental, environmental, behavioral, and social factors, and the appropriate treatment varies by the individual and condition.

Medical services

Medical services may be furnished by physicians and other qualified health professionals within their state scope of practice and the requirements of the applicable payer.

Potential provider types may include:

  • Physicians, including MDs and DOs
  • Nurse practitioners
  • Physician assistants
  • Certified nurse-midwives
  • Clinical nurse specialists
  • Registered nurses
  • Physical, occupational, and speech-language professionals
  • Other licensed or qualified professionals

Prescribing, diagnosing, ordering, supervising, and billing authority vary by profession, jurisdiction, service, and payer.

Laboratory services

Organizations performing laboratory testing on human specimens may be subject to Clinical Laboratory Improvement Amendments (CLIA) requirements.

The level of certification and personnel qualifications depends in part on the type and complexity of testing.

Do not rely on a generic occupational title such as "licensed medical technician" to determine whether laboratory requirements are met.

Educational and developmental services

Requirements for educational assessment and specialized educational services depend on the school system, jurisdiction, funding source, professional role, and applicable special-education requirements.

Payer eligibility and professional qualification should be verified for the particular service rather than assuming every educational service requires the same credential.

Organizational enrollment and credentialing

Third-party reimbursement often requires more than employing appropriately licensed professionals.

The organization and individual practitioners may need:

  • National Provider Identifiers (NPIs)
  • Payer enrollment
  • Credentialing
  • Network contracts
  • Practice-location approval
  • Ownership and control disclosures
  • Licensure or certification
  • Accreditation where required
  • Periodic revalidation

Medicare

Medicare provider enrollment generally involves:

  1. Obtaining the appropriate NPI
  2. Completing enrollment through the Medicare Provider Enrollment, Chain, and Ownership System (PECOS) or another permitted application process
  3. Paying an enrollment application fee when one applies
  4. Working with the appropriate Medicare Administrative Contractor
  5. Keeping enrollment information current
  6. Revalidating enrollment when required

Enrollment requirements differ according to provider or supplier type.

Medicaid

Medicaid provider enrollment is administered through state programs within federal requirements.

Participating providers are subject to screening and enrollment requirements, and state procedures may differ considerably.

Medicaid managed care plans may also have contracting or credentialing processes in addition to state enrollment requirements.

Commercial payers

Private plans may require separate:

  • Credentialing
  • Contracting
  • Network participation
  • Provider-directory information
  • Recredentialing

Enrollment with one payer does not automatically make an organization eligible to bill another.

Does an organization need 501(c)(3) status?

Not necessarily.

Federal tax-exempt status and provider reimbursement eligibility are separate concepts.

Some particular grants, contracts, programs, or public funding arrangements may require nonprofit or tax-exempt status, but many health care providers receiving third-party reimbursement operate under other organizational structures.

Nonprofit incorporation also does not automatically create federal income-tax exemption.

Organizations seeking recognition under section 501(c)(3) generally must meet federal requirements and, in most circumstances, apply to the Internal Revenue Service for recognition of exemption.

Federal tax exemption also does not automatically provide exemption from every state or local sales, property, or other tax. Those requirements vary by jurisdiction.

Facility, accessibility, technology, and privacy requirements

Requirements may apply to both physical and virtual service settings.

Accessibility

Health and human service organizations should provide access for people with disabilities consistent with the laws and requirements applicable to them.

Depending on the setting, considerations may include:

  • Accessible routes and entrances
  • Accessible restrooms
  • Accessible examination rooms and equipment
  • Appropriate communication access for Deaf and hard-of-hearing people
  • Materials accessible to people with visual, cognitive, or other disabilities
  • Reasonable modifications to policies and procedures where required

Accessibility should not be treated merely as a credentialing task. It is part of providing equitable access to services.

Privacy and confidentiality

Third-party billing may require collecting and transmitting sensitive health and financial information.

Organizations should determine whether they are covered entities or business associates under HIPAA and what other federal and state privacy rules apply.

Appropriate safeguards may include:

  • Role-based access
  • Secure electronic systems
  • Privacy policies
  • Workforce training
  • Secure communication
  • Business associate agreements where required
  • Risk assessment
  • Breach-response procedures

Protect privacy in physical spaces as well as electronic systems.

Telehealth and remote services

Some services may be delivered through telehealth or other remote methods when permitted.

Before billing, verify:

  • Payer coverage
  • Provider licensure
  • Participant location requirements
  • Approved technology
  • Coding
  • Documentation
  • Privacy
  • Consent requirements

Telehealth requirements can change, so organizations should monitor current payer and regulatory guidance.

Billing and documentation requirements

Becoming enrolled or credentialed does not by itself create a successful reimbursement system.

The organization needs a reliable revenue-cycle process.

Verify coverage and eligibility

Before providing a billable service when practical, determine:

  • Whether coverage is active
  • Whether the provider is in network or otherwise eligible
  • Whether the service is covered
  • Whether authorization or referral is required
  • What participant cost sharing may apply

Obtain prior authorization when required

Some payers require approval before specified services, procedures, medications, or levels of care are provided.

Authorization does not always guarantee payment, but failing to obtain a required authorization can result in denial.

Track:

  • Authorization numbers
  • Approved services
  • Units or visits
  • Effective dates
  • Expiration dates
  • Renewal requirements

Document services accurately

Records should support the services billed and meet applicable clinical, professional, payer, and legal requirements.

Documentation may need to support:

  • Service date
  • Provider
  • Service performed
  • Diagnosis or other eligibility information when applicable
  • Medical necessity or program criteria
  • Duration or units
  • Treatment or service plan
  • Outcomes or response when required

Document the service because it is clinically and administratively necessary, not simply to maximize reimbursement.

Code accurately

Health care claims may require CPT, HCPCS, ICD-10-CM, revenue, place-of-service, modifier, or other coding depending on the payer and service.

Coding should accurately reflect the service documented.

Do not bill a higher-level or different service merely because it produces a higher payment.

Submit claims and manage remittances

Establish systems for:

  • Electronic claim submission
  • Claim-status tracking
  • Payment posting
  • Contractual adjustments
  • Participant balances
  • Denials
  • Corrected claims
  • Appeals
  • Refunds and overpayments

Monitor denials

Denials are not just individual billing problems. Patterns can reveal weaknesses in:

  • Eligibility verification
  • Authorization
  • Documentation
  • Coding
  • Credentialing
  • Contract setup
  • Staff training

Track denial reasons and address recurring causes.

How do you prepare to pursue third-party reimbursement?

1. Define which services you want to finance

Begin with mission and community need rather than with the payer.

Identify:

  • The services to be provided
  • Who needs them
  • Current costs
  • Current funding sources
  • Why reimbursement may be appropriate

2. Identify relevant payers

Determine which health plans, public programs, agencies, schools, or other entities cover the services used by the people your organization serves.

3. Research each payer's requirements

Obtain current information directly from the payer or authoritative program guidance.

Review:

  • Covered services
  • Provider eligibility
  • Credentialing
  • Enrollment
  • Network requirements
  • Rates
  • Prior authorization
  • Coding
  • Billing
  • Documentation
  • Appeals
  • Audit provisions
  • Termination provisions

4. Assess the organization's readiness

Review:

  • Staff credentials
  • Clinical or service capacity
  • Facilities
  • Accessibility
  • Technology
  • Privacy and security
  • Financial systems
  • Billing systems
  • Compliance
  • Cash reserves

5. Model the financial impact

Estimate:

  • Expected payer mix
  • Contracted or allowed rates
  • Expected volume
  • Denials
  • Participant cost sharing
  • Billing costs
  • Credentialing costs
  • Technology costs
  • Additional staffing
  • Payment delays

Compare expected net reimbursement with the full cost of providing and administering the service.

6. Plan for workforce changes

If additional credentials or expertise are needed, determine whether to:

  • Hire staff
  • Increase supervision
  • Contract appropriately with qualified professionals
  • Partner with another organization

Compensation, workload, professional development, supervision, and working conditions should support recruitment and retention.

7. Build the required infrastructure

This may include:

  • Electronic health or service records
  • Billing software
  • Clearinghouse relationships
  • Compliance policies
  • Privacy and security safeguards
  • Credentialing systems
  • Financial controls
  • Quality-improvement systems

8. Complete enrollment, credentialing, and contracting

Complete all required steps before assuming the organization may submit payable claims.

Verify:

  • Effective date
  • Billing privileges
  • Network status
  • Authorized locations
  • Individual provider enrollment or reassignment where required

9. Train staff before billing begins

Staff should understand:

  • Covered services
  • Documentation
  • Coding
  • Prior authorization
  • Privacy
  • Billing compliance
  • Participant financial communication

10. Communicate with participants

Explain clearly:

  • Which coverage the organization accepts
  • Network status when known
  • What services may be covered
  • Potential deductibles, copayments, or other costs
  • Financial-assistance options
  • What happens if coverage changes

Avoid promising that insurance will pay simply because a service has been scheduled or authorized.

11. Start carefully and monitor performance

Organizations may benefit from implementing reimbursement in stages rather than immediately depending on it for a large share of operating revenue.

Monitor:

  • Claims submitted
  • Payments
  • Denials
  • Accounts receivable
  • Administrative costs
  • Staff workload
  • Participant access
  • Service quality
  • Mission impact

Maintaining payer relationships and compliance

Communication with payers matters, but payer relationships should be professional, documented, and compliant.

Do not rely on personal relationships to obtain faster payment, avoid requirements, or have rules "bent."

Designate appropriate responsibility

Depending on organizational size and billing volume, responsibilities may include:

  • Provider enrollment
  • Credentialing
  • Contract management
  • Revenue-cycle management
  • Claims
  • Denials and appeals
  • Compliance

Smaller organizations may combine these responsibilities or use qualified external support.

Use formal payer channels

Maintain current contacts for:

  • Provider relations
  • Credentialing
  • Contracting
  • Claims
  • Prior authorization
  • Appeals

Document important payer communications and contract interpretations.

Monitor policy changes

Third-party reimbursement changes continually.

Monitor changes involving:

  • Coverage
  • Fee schedules and contracted rates
  • Coding
  • Prior authorization
  • Provider enrollment
  • Revalidation
  • Telehealth
  • Documentation
  • Electronic transactions
  • Interoperability
  • Privacy and cybersecurity

Maintain enrollment information

Report changes within required timeframes and complete recredentialing or revalidation when required.

Failure to maintain current enrollment may interrupt billing privileges or payment.

Maintain a compliance program

Organizations should establish processes for identifying and correcting billing or documentation problems.

This may include:

  • Policies and procedures
  • Staff training
  • Internal auditing
  • Coding review
  • Denial analysis
  • Overpayment identification and response
  • Processes for reporting concerns

Continue evaluating whether third-party reimbursement supports the mission

Third-party billing is a financing tool, not an organizational purpose.

Periodically evaluate:

  • Net revenue
  • Administrative burden
  • Payment delays
  • Denial rates
  • Staff workload
  • Service quality
  • Participant access
  • Equity
  • Mission alignment

An organization may decide to add a payer, leave a network, renegotiate a contract, limit certain reimbursable services, increase alternative funding for people without coverage, or stop billing a payer when the arrangement no longer supports sustainable and effective service delivery.

In Summary

Third-party reimbursement can provide an important recurring source of revenue for community organizations that deliver eligible health, behavioral health, educational, rehabilitation, or other covered services.

It can improve access by reducing what participants must pay directly and can help integrate an organization into broader service systems. It can also require substantial investment in staff credentials, enrollment, billing, technology, accessibility, privacy, documentation, compliance, and financial management.

Payment is not guaranteed simply because a covered service was provided. Eligibility, authorization, network status, documentation, coding, medical necessity, timely filing, audits, and other requirements may affect whether and when payment occurs.

Determine reimbursement eligibility separately for each payer, service, provider type, setting, and participant. Do not rely on broad lists of services or professional credentials that may be outdated or inapplicable to a particular program.

Before billing begins, understand the full cost of participation, complete required enrollment and credentialing, establish appropriate clinical and administrative systems, protect participant information, train staff, and plan for denials and payment delays.

Third-party billing should also be evaluated for equity. Organizations should consider how services will remain accessible to people who are uninsured, underinsured, out of network, or otherwise unable to obtain reimbursement.

Finally, continue evaluating whether reimbursement supports the organization's mission. Sustainable financing should help the organization provide effective and accessible services; the organization should not redesign its purpose simply around what a payer is willing to reimburse.

Resources

Online Resources

Most of the following resources are examples -- of client eligibility criteria, of administrative requirements, of certification requirements for various practitioners.

The Division of Special Services for Children at the University of Illinois, Chicago. In the Providers section, there are good examples of the kinds of criteria a payer might set. In addition, the descriptions of various programs give client eligibility criteria.

https://ctb.ku.edu/en/table-of-contents/sustain/long-term-sustainability/third-party-funding/main
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