Biomedical Engineering Reference
In-Depth Information
operations, such as costs associated with relocating
patients from an evacuated building.
bursement from the party who received the
goods or services (or from some other source)?
Are the tools necessary to track such outgoing
items (including, but not limited to, a pen and
paper) available to the Logistics Section Chief
in during a response?
A. Cash Flow
Regardless of whether they are operated on a
for-profit or nonprofit basis, healthcare institu-
tions depend upon regular cash flow to remain
operational. The majority of income for most
healthcare institutions comes from patient insur-
ance reimbursement (either private or government-
sponsored). An emergency may interrupt the usual
revenue cycle, either due to loss of the institu-
tion's computer system or a more general local or
regional event.
Accordingly, the continued financial operations
of a hospital are dependent primarily on an ability
to document and bill for services provided during
an emergency in a manner that closely approx-
imates the documentation that is used for usual
operations.
B. Patient Insurance Coverage
Healthcare organizations should review third-party
payor agreements, as well as examine what other
funding sources may exist to cover treatment
rendered to patients during an emergency situation.
1. Do private health-insurance policies provide
for coverage for treatment mandated by public
health authorities (e.g., in the case of isolation)?
a.
Is such treatment covered by a private
payor, Medicaid, Medicare, or the Federal
Employees Health Benefits
Program
(FEHBP)?
b. Can a determination of medical neces-
sity by a public health authority trump a
determination to the contrary by a private
payor?
c. Are prior authorization/precertification
requirements waived in the event of a
major disaster or emergency?
d. Do payor agreements contain a
force
majeure
clause that references epidemics
or other public health emergencies as
excluded events?
e. Are Medicare Disproportionate Share
(DSH) payments
48
or other similar funds
available to cover the costs of this treat-
ment if private-payor coverage falls short?
f. Can institutions address these issues in
provider agreements with health plans?
2. What other funding sources are available to the
institution?
a. Is business-interruption insurance avail-
able?
b. Does the county or state have funds
to compensate an institution if private
coverage is insufficient?
1. Does the institution's emergency-management
planning establish how to conduct billing when
the computer system (or other infrastructure
components) is compromised? Can personnel
print out blank screens from the computer
system, complete them by hand, and then back-
load the data entry once the crisis passes?
2. If full documentation for billing purposes is
not available, are methods for recordkeeping
sufficient to retroactively establish services
rendered, either (i) for purposes of billing
third-party payors who would accept billing
based on such records and/or (ii) claims
under business-inter-ruption insurance policies
and/or governmental grant programs?
3. Are potential recordkeeping methods varied
to enable a confirmation of services through
multiple records?
4. To the extent that the institution needs to
provide goods and supplies to other respon-
ders, has the institution determined how it will
keep track of what has been provided, and at
what cost, in order to obtain subsequent reim-
48
See
42 C.F.R. ยงยง 412.106, 447.272(c)(2) (2004).
