| Title:
Copays: What to Charge, When to Waive, & How to Collect
Presenter: Rachel Rose, JD, MBA
Time: 59.37 minutes
Description: It can be difficult for patients to navigate the different types of payments in health insurance. Rachel Rose, Attorney at Law, discusses safeguards, policies and procedures, and training that need to be in place for an adequate compliance program in order to mitigate fraud, waste, and abuse liability.
Objectives:
- Discuss Copays-determining amounts, collecting, and waiving.
- Recognize liability associated with not collecting copays in a variety of scenarios.
- Understand the role of compliance.
Key Topics:
- Recap of Key Terms
- Explanation of Benefits
- McCarran-Ferguson Act
- Copays – Definition, Dos and Don'ts
- Copays Versus Deductible
- Coinsurance
- Coordination of Benefits
- How is a Copay Amount Determined?
- Collecting Copays
- Collecting Copays – Verify
- A Structured Approach to Collecting Patient A/R
- How You Say It Makes a Difference
- Appropriate Waiver of Copays
- Potential Areas of Liability
- Fraud, Waste, and Abuse Laws
- The False Claims Act
- Liability for Certain Acts
- What Does “Material” Mean?
- 2020 – Apria Healthcare for Fraudulent Billing Practices
- The Role of Compliance in Mitigating Risk
- Compliance Programs in Healthcare
- DOJ's 2020 Guidance for Evaluating Compliance
- DOJ's 2023 Guidance for Evaluating Compliance
- Concluding Items
- Presentation Pointers
Speaker Rachel V. Rose, JD, MBA - Principal. https://www.rvrose.com/ Ms. Rose has a unique background. Throughout her career, she has accumulated knowledge in a multitude of fields, with an emphasis on various facets of healthcare. Her experiences include: - working on Wall Street and at one of the "Big Four" consulting firms;
- producing for the Chairman of the Reform and Oversight Committee on Capitol Hill;
- interning at the Department of Health and Human Services;
- compiling policy papers at the Royal College of Nursing in London;
- consultative work as a top performing representative for the pharmaceutical and medical device industry;
- clerking for the Honorable Linda R. Allan (6th Judicial Circuit, FL).
Prior to opening her law firm, she was Director of Business Development and Assistant General Counsel for a healthcare advisory company. She is extensively published and presents on a variety of healthcare, False Claims Act and securities law topics including: cybersecurity, qui tam, physician reimbursement, ICD-10, access to care, anti-kickback and Stark laws, U.S. Supreme Court cases impacting the medical device industry, international comparative healthcare laws, and the HIPAA/the HITECH Act.
Presently, she is the immediate past-chair of the Federal Bar Association's Corporate and Associations Counsel Division (2014-2016), one of eighteen lawyers, who serves on the Federal Bar Association's Government Relations Committee. Ms. Rose has co-authored The American Bar Association's books - The ABCs of ACOs and What Are International HIPAA Considerations?, as well as being a co-editor of American Health Lawyers Association’s Enterprise Risk Management Handbook (2nd Edition). Ms. Rose is also an Affiliated Member of the Baylor College of Medicine's Center for Health Policy and Medical Ethics, where she teaches bioethics and is on the University of Houston Law School's Healthcare Law Advisory Board.
Education - Bachelor of Arts- History (The Pennsylvania State University)
- Master of Business Administration (Vanderbilt University)
- Doctorate of Jurisprudence (Stetson University College of Law); Editor, The Journal of International Law and Aging
Honors and Awards - National Scribes Award
- The William F. Blews Pro Bono Service Award
- Federal Bar Association Fellow
- Named to Texas Bar College
- National Women Trial Lawyers Association - Top 25,, 2018 and 2019
- Houstonia Magazine's Top Lawyers- Healthcare Law, 2018 and 2019
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