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Testimony:

Before the Subcommittee on Oversight and Investigations, Committee on 
Veterans' Affairs, House of Representatives:

United States General Accounting Office:

GAO:

For Release on Delivery Expected at 2:00 p.m.

Wednesday, May 7, 2003:

VA Health Care:

VA Increases Third-Party Collections as It Addresses Problems in Its 
Collections Operations:

Statement of Cynthia A. Bascetta:

Director, Health Care--Veterans':

Health and Benefits Issues:

GAO-03-740T:

Highlights of GAO-03-740T, a testimony before the Subcommittee on 
Oversight and Investigations, Committee on Veterans’ Affairs, House of 
Representatives 

GAO Highlights:

The Department of Veterans Affairs  (VA) collects health insurance 
payments, known as third-party collections, for veterans’ health care 
conditions it treats that are not a result of injuries or illnesses 
incurred or aggravated during military service.  In September 1999, VA 
adopted a new fee schedule, called “reasonable charges,” that it 
anticipated would increase revenues from third-party collections.

In January 2003, GAO reported on VA’s third-party collection efforts 
and problems in collections operations for fiscal year 2002 as well as 
VA’s initiatives to improve collections (VA Health Care:  Third-Party 
Collections Rising as VA Continues to Address Problems in Its 
Collections Operations, [GAO-03-145, Jan. 31, 2003]).  GAO was asked to 
discuss its findings and update third-party collection amounts and 
agency plans to improve collections.

Why GAO Did This Study:

The Department of Veterans Affairs  (VA) collects health insurance 
payments, known as third-party collections, for veterans’ health care 
conditions it treats that are not a result of injuries or illnesses 
incurred or aggravated during military service.  In September 1999, VA 
adopted a new fee schedule, called “reasonable charges,” that it 
anticipated would increase revenues from third-party collections.

In January 2003, GAO reported on VA’s third-party collection efforts 
and problems in collections operations for fiscal year 2002 as well as 
VA’s initiatives to improve collections (VA Health Care:  Third-Party 
Collections Rising as VA Continues to Address Problems in Its 
Collections Operations, [GAO-03-145, Jan. 31, 2003]).  GAO was asked to 
discuss its findings and update third-party collection amounts and 
agency plans to improve collections.

What GAO Found:

VA’s fiscal year 2002 third-party collections rose by 32 percent over 
fiscal year 2001 collections, to $687 million, and available data for 
the first half of fiscal year 2003 show that $386 million has been 
collected so far.  The increase in collections reflects VA’s improved 
ability to manage the larger billing volume and more itemized bills 
required under its new fee schedule.  VA managers in three regional 
health care networks attributed billings increases to a reduction of 
billing backlogs and improved collections processes, such as better 
medical documentation prepared by physicians, more complete 
identification of billable care by coders, and more bills prepared per 
biller.  

Although collections are increasing, operational problems, such as 
missed billing opportunities, persist and continue to limit the amount 
VA collects.  VA has been implementing the action items in its Revenue 
Cycle Improvement Plan of September 2001 that are designed to address 
operational problems, such as unidentified insurance for some patients, 
insufficient documentation of services for billing, shortages of 
billing staff, and insufficient pursuit of accounts receivable.  VA 
reported in April 2003 that 10 of 24 action items are complete; 7 are 
scheduled for implementation by the end of 2003; and the remaining 
actions will begin in 2004 with full implementation expected in 2005 or
2006.  These dates are behind VA’s original schedule.  In addition, the 
Chief Business Office, established in May 2002, has developed a new 
approach that combines the action items with additional initiatives.  

Given the growing demand for care, especially from higher-income 
veterans, it is important that VA resolve its operational problems and 
sustain its commitment to maximizing third-party collections.  It is 
also important for VA to develop a reliable estimate of uncollected 
dollars and a complete measure of its collections costs.  Without this 
information, VA cannot evaluate its effectiveness in supplementing its 
medical care appropriation with third-party dollars.  

www.gao.gov/cgi-bin/getrpt?GAO-03-740T.

To view the full testimony click on the link above.  For more 
information, contact Cynthia A. Bascetta at (202) 512-7101.

[End of section]

Mr. Chairman and Members of the Subcommittee:

I am pleased to be here today to discuss the Department of Veterans 
Affairs' (VA) progress in collecting insurance payments for care 
provided at VA facilities from eligible veterans' private health 
insurers. Known as third-party collections, these collections are VA's 
largest source of revenue to supplement its medical care appropriation, 
and they help pay for veterans' growing demand for care. The total 
number of veterans VA treated has increased from 2.6 million in fiscal 
year 1996 to 4.3 million in fiscal year 2002, and VA predicts 
continuing growth in its patient workload. Higher income veterans or 
those without service-connected disabilities have comprised a 
significant portion of this growth, and third-party collections are 
intended to help pay for the cost of their care.

Over the past several years, concerns have been raised about VA's 
ability to maximize its third-party collections to enhance revenues. We 
testified in September 2001 that problems in VA's collections 
operations--such as inadequate patient intake procedures to gather 
insurance information, insufficient physician documentation, a 
shortage of qualified coders, and insufficient automation--diminished 
VA's collections.[Footnote 1] Concerned about these issues you asked 
that we report on (1) trends in VA's third-party collections, (2) 
problems in collections operations, and (3) VA's approach for improving 
collections. My comments today are based on a report we issued to this 
subcommittee on January 31, 2003.[Footnote 2] For that work, we 
examined VA's collections data for fiscal years 2001 and 2002 and 
available data for 2003; reviewed relevant VA documents, such as the 
Veterans Health Administration's (VHA) Revenue Cycle Improvement Plan 
of September 2001; and interviewed officials in VA headquarters and in 
3 of VA's 21 health care networks[Footnote 3]--Network 2 (Albany), 
Network 9 (Nashville), and Network 22 (Long Beach). At your request, we 
updated information in that report on third-party collection amounts 
and agency plans to improve collections. We did our work in accordance 
with generally accepted government auditing standards.

In summary, VA's third-party collections for fiscal year 2002 totaled 
$687 million, 32 percent more than for fiscal year 2001, and available 
data for the first half of fiscal year 2003 show that $386 million has 
been collected so far. Although VA reported an increase in collections, 
we found that operational problems, such as missed billing 
opportunities, continued to limit collections. As a result, VA lacks a 
reliable estimate of uncollected dollars and therefore does not have 
the basis to assess its systemwide operational effectiveness. In May 
2002, VA established the Chief Business Office (CBO) in VHA to develop 
a new approach for VA's collections activity. VA officials told us that 
CBO's approach would combine the VHA Revenue Cycle Improvement Plan of 
September 2001 (2001 Improvement Plan) with additional initiatives, 
such as the development of an automated financial system that better 
serves billing needs and additional performance measures and standards 
for overseeing collection units' activities. Since the introduction of 
the 2001 Improvement Plan, VA has made some progress in resolving 
operational problems, such as fully implementing electronic billing, 
mandating the use of electronic medical records, and using 
preregistration software. However, given today's tight budget 
environment, it is important that VA resolve its operational problems 
and sustain its attention and commitment to maximizing third-party 
collections.

Background:

Although VA has been authorized to collect third-party health insurance 
payments since 1986, it was not allowed to use these funds to 
supplement its medical care appropriations until enactment of the 
Balanced Budget Act of 1997. Part of VA's 1997 strategic plan was to 
increase health insurance payments and other collections to help fund 
an increased health care workload. The potential for increased workload 
occurred in part because the Veterans' Health Care Eligibility Reform 
Act of 1996 authorized VA to provide certain medical care services not 
previously available to higher-income veterans or those without 
service-connected disabilities. VA expected that the majority of the 
costs of their care would be covered by collections from third-party 
payments, copayments, and deductibles. These veterans increased from 
about 4 percent of all veterans treated in fiscal year 1996 to about a 
quarter of VA's total patient workload in fiscal year 2002.

VA can bill insurers for treatment of conditions that are not a result 
of injuries or illnesses incurred or aggravated during military 
service. However, VA cannot bill them for health care conditions that 
result from military service, nor is it generally authorized to collect 
from Medicare or Medicaid, or from health maintenance organizations 
when VA is not a participating provider.

To collect from health insurers, VA uses five related processes to 
manage the information needed to bill and collect. The patient intake 
process involves gathering insurance information and verifying that 
information with the insurer. The medical documentation process 
involves properly documenting the health care provided to patients by 
physicians and other health care providers. The coding process involves 
assigning correct codes for the diagnoses and medical procedures based 
on the documentation. Next, the billing process creates and sends bills 
to insurers based on the insurance and coding information. Finally, the 
accounts receivable process includes processing payments from insurers 
and following up with insurers on outstanding or denied bills.

In September 1999, VA adopted a fee schedule, called "reasonable 
charges." Reasonable charges are itemized fees based on diagnoses and 
procedures. This schedule allows VA to more accurately bill for the 
care provided. However, by making these changes, VA created additional 
bill-processing demands--particularly in the areas of documenting care, 
coding that care, and processing bills per episode of care. First, VA 
must accurately assign medical diagnoses and procedure codes to set 
appropriate charges, a task that requires coders to search through 
medical documentation and various databases to identify all billable 
care. Second, VA must be prepared to provide an insurer supporting 
medical documentation for the itemized charges. Third, in contrast to a 
single bill for all the services provided during an episode of care 
under the previous fee schedule, under reasonable charges VA must 
prepare a separate bill for each provider involved in the care and an 
additional bill if a hospital facility charge applies.

Third-Party Collections Increased:

For fiscal year 2002, VA collected $687 million in insurance payments, 
up 32 percent compared to the $521 million collected during fiscal year 
2001. Collections through the first half of fiscal year 2003 total $386 
million in third-party payments. The increased collections in fiscal 
year 2002 reflected that VA processed a higher volume of bills than it 
did in the prior fiscal year. VA processed and received payments for 
over 50 percent more bills in fiscal year 2002 than in fiscal year 
2001. VA's collections grew at a lower percentage rate than the number 
of paid bills because the average payment per paid bill dropped 18 
percent compared to the prior fiscal year. Average payments dropped 
primarily because a rising proportion of VA's paid bills were for 
outpatient care rather than inpatient care. Since the charges for 
outpatient care were much lower on average, the payment amounts were 
typically lower as well.

Although VA anticipated that the shift to reasonable charges in 1999 
would yield higher collections, collections had dropped in fiscal year 
2000. VA attributed that drop to its being unprepared to bill under 
reasonable charges, particularly because of its lack of proficiency in 
developing medical documentation and coding to appropriately support a 
bill. As a result, VA reported that many VA medical centers developed 
billing backlogs after initially suspending billing for some care.

As shown in figure 1, VA's third-party collections increased in fiscal 
year 2001--reversing fiscal year 2000's drop in collections--and 
increased again in fiscal year 2002. After initially being unprepared 
in fiscal year 2000 to bill reasonable charges, VA began improving its 
implementation of the processes necessary to bill and increase its 
collections. By the end of fiscal year 2001, VA had submitted 37 
percent more bills to insurers than in fiscal year 2000. VA submitted 
even more in fiscal year 2002, as over 8 million bills--a 54 percent 
increase over the number in fiscal year 2001--were submitted to 
insurers.

Figure 1: VA's Third-Party Collections, Fiscal Years 1997 through 2002:

[See PDF for image]

[End of figure]

Managers we spoke with in three networks--Network 2 (Albany), Network 9 
(Nashville), and Network 22 (Long Beach)--mainly attributed the 
increased billings to reductions in the billing backlogs. Networks 2 
(Albany) and 9 (Nashville) reduced backlogs, in part by hiring more 
staff, contracting for staff, or using overtime to process bills and 
accounts receivable. Network 2 (Albany), for instance, managed an 
increased billing volume through mandatory overtime. Managers we 
interviewed in all three networks noted better medical documentation 
provided by physicians to support billing. In Network 22 (Long Beach) 
and Network 9 (Nashville), revenue managers reported that coders were 
getting better at identifying all professional services that can be 
billed under reasonable charges.[Footnote 4] In addition, the revenue 
manager in Network 2 (Albany) said that billers' productivity had risen 
from 700 to 2,500 bills per month over a 3-year period, as a result of 
gradually increasing the network's productivity standards and 
streamlining their jobs to focus solely on billing.

VA officials cited other reasons for the increased number of bills 
submitted to insurers. An increased number of patients with billable 
insurance was one reason for the increased billing. In addition, a May 
2001 change in the reasonable-charges fee schedule for medical 
evaluations allowed separate bills for facility charges and 
professional service charges, a change that contributed to the higher 
volume of bills in fiscal year 2002.

Operational Problems Limit Collections, but VA Lacks an Estimate of 
Uncollected Dollars:

Studies have suggested that operational problems--missed billing 
opportunities, billing backlogs, and inadequate pursuit of accounts 
receivable--limited VA's collections in the years following the 
implementation of reasonable charges. For example, a study completed 
last year estimated that 23.8 percent of VA patients in fiscal year 
2001 had billable care, but VA actually billed for the care of only 
18.3 percent of patients.[Footnote 5] This finding suggests that VA 
could have billed for 30 percent more patients than it actually billed. 
Further, after examining activities in fiscal years 2000 and 2001, a VA 
Inspector General report estimated that VA could have collected over 
$500 million more than it did.[Footnote 6] About 73 percent of this 
uncollected amount was attributed to a backlog of unbilled medical 
care; most of the rest was attributed to insufficient pursuit of 
delinquent bills. Another study, examining only professional-service 
charges in a single network, estimated that $4.1 million out of $4.7 
million of potential collections was unbilled for fiscal year 
2001.[Footnote 7] Of that unbilled amount, 63 percent was estimated to 
be unbillable primarily because of insufficient documentation. In 
addition, the study found that coders often missed services that should 
have been coded for billing.

According to a CBO official, VA could increase collections by working 
on operational problems. These problems included unpaid accounts 
receivable and missed billing opportunities due to insufficient 
identification of insured patients, inadequate documentation to support 
billing, and coding problems that result in unidentified care. From 
April through June 2002, three network revenue managers told us about 
backlogs and processing issues that persisted into fiscal year 2002. 
For example, although Network 9 (Nashville) had above average increases 
in collections for both inpatient and outpatient care, it still had 
coding backlogs in four of six medical centers. According to Network 
9's (Nashville) revenue manager, eliminating the backlogs for 
outpatient care would increase collections by an estimated $4 million, 
or 9 percent, for fiscal year 2002.[Footnote 8] Additional increases 
might come from coding all inpatient professional services, but the 
revenue manager did not have an estimate because the extent to which 
coders are capturing all billable services was unknown. Moreover, 
although all three networks reported that physicians' documentation for 
billing was improving, they also reported a continuing need to improve 
physicians' documentation. In addition, Network 22 (Long Beach) 
reported that its accounts receivable staff had difficulties keeping up 
with the increased volume of bills because it had not hired additional 
staff members or contracted help on accounts receivable.

As a result of these operational limitations, VA lacks a reliable 
estimate of uncollected dollars, and therefore does not have the basis 
to assess its systemwide operational effectiveness. For example, some 
uncollected dollars result from billing backlogs and billable care 
missed in coding. In addition, VA does not know the net impact of 
actual third-party collections on supplementing its annual 
appropriation for medical care. For example, CBO relies on reported 
cost data from central office and field staff directly involved in 
billing and collection functions. However, these costs do not include 
all costs incurred by VA in the generation of revenue. According to a 
CBO official, VA does not include in its collections cost the 
investments it has made in information technology or resources used in 
the identification of other health insurance during the enrollment 
process.

2001 Plan to Improve Collections Is Partially Implemented; Other 
Initiatives Being Developed:

VA continues to implement its 2001 Improvement Plan, which is designed 
to increase collections by improving and standardizing VA's collections 
processes. The plan's 24 actions are to address known operational 
problems affecting revenue performance. These problems include 
unidentified insurance for some patients, insufficient documentation 
for billing, coding staff shortages, gaps in the automated capture of 
billing data, and insufficient pursuit of accounts receivable. The plan 
also addresses uneven performance across collection sites.

The plan seeks increased collections through standardization of policy 
and processes in the context of decentralized management, in which VA's 
21 network directors and their respective medical center directors have 
responsibility for the collections process. Since management is 
decentralized, collections procedures can vary across sites. For 
example, sites' procedures can specify a different number of days 
waited until first contacting insurers about unpaid bills and can vary 
on whether to contact by letter, telephone, or both. The plan intends 
to create greater process standardization, in part, by requiring 
certain collections processes, such as the use of electronic medical 
records by all networks to provide coders better access to 
documentation and legible records.

When fully implemented, the plan's actions are intended to improve 
collections by reducing operational problems, such as missed billing 
opportunities. For example, two of the plan's actions--requiring 
patient contacts to gather insurance information prior to scheduled 
appointments and electronically linking VA to major insurers to 
identify patients' insurance--are intended to increase VA's awareness 
of its patients who have other health insurance.

VA has implemented some of the improvement plan's 24 actions, which 
were scheduled for completion at various times through 2003, but is 
behind the plan's original schedule. The plan had scheduled 15 of the 
24 actions for completion through May 25, 2002, but as of that date VA 
had only completed 8 of the actions. Information obtained from CBO in 
April 2003 indicates that 10 are complete and 7 are scheduled for 
implementation by the end of 2003. Implementation of the remaining 
actions will begin in 2004 as part of a financial system pilot with 
full implementation expected in 2005 or 2006.[Footnote 9] (Appendix I 
lists the actions and those VA reports as completed through April 28, 
2003.):

In May 2002, VHA established its CBO to underscore the importance of 
revenue, patient eligibility, and enrollment and to give strategic 
focus to improving these functions. Officials in the office told us 
that they have developed a new approach for improving third-party 
collections that can help increase revenue collections by further 
revising processes and providing a new business focus on collections.

For example, the CBO's strategy incorporates improvements to the 
electronic transmission of bills and initiation of a system to receive 
and process third-party payments electronically. CBO's new approach 
also encompasses initiatives beyond the improvement plan, such as the 
one in the Under Secretary for Health's May 2002 memorandum that 
directed all facilities to refer accounts receivable older than 60 days 
to a collection agency, unless a facility can document a better in-
house process. According to the Deputy Chief Business Officer, the use 
of collection agencies has shown some signs of success--with 
outstanding accounts receivables dropping from $1,378 million to $1,317 
million from the end of May to the end of July 2002, a reduction of 
about $61 million or 4 percent.

CBO is in the process of acquiring a standardized Patient Financial 
Services System (PFSS) that could be shared across VA. VA's goal with 
PFSS is to implement a commercial off-the-shelf health care billing and 
accounts receivable software system. Under PFSS, a unique record will 
be established for each veteran. Patient information will be 
standardized--including veteran insurance data, which will be 
collected, managed, and verified. Receipts of health care products and 
services will be added to the patient records as they are provided or 
dispensed. And PFSS will automatically extract needed data for billing, 
with the majority of billings sent to payers without manual 
intervention. After the system is acquired, VA will conduct a 
demonstration project in Network 10 (Cincinnati).[Footnote 10]

According to the Deputy Chief Business Officer, in May 2003 VA 
anticipates awarding a contract for the development and implementation 
of PFSS. CBO's plan is to install this automated financial system in 
other facilities and networks if it is successfully implemented in the 
pilot site.

CBO is taking action on a number of other initiatives to improve 
collections, including the following:

* Planning and developing software upgrades to facilitate the health 
care service review process and electronically receive and respond to 
requests from insurers for additional documentation.

* Establishing the Health Revenue Center to centralize preregistration, 
insurance identification and verification, and accounts receivable 
activities. For example, during a preregistration pilot in Network 11 
(Ann Arbor), the Health Revenue Center made over 246,000 
preregistration telephone calls to patients to verify their insurance 
information. According to VA, over 23,000 insurance policies were 
identified, resulting in 
$4.8 million in collections.

* Assessing its performance based on private sector performance 
metrics, including measuring the pace of collections relative to the 
amount of accounts receivable.

Concluding Observations:

As VA faces increased demand for medical care, particularly from 
higher-income veterans, third-party collections for nonservice-
connected conditions remain an important source of revenue to 
supplement VA's appropriations. VA has been improving its billing and 
collecting under a reasonable-charges fee schedule it established in 
1999, but VA has not completed its efforts to address problems in 
collections operations. In this regard, fully implementing the 2001 
Improvement Plan could help VA maximize future collections by 
addressing problems such as missed billing opportunities. CBO's 
initiatives could further enhance collections by identifying root 
causes of problems in collections operations, providing a focused 
approach to addressing the root causes, establishing performance 
measures, and holding responsible parties accountable for achieving the 
performance standards.

Our work and VA's continuing initiatives to improve collections 
indicate that VA has not collected all third-party payments to which it 
is entitled. In this regard, it is important that VA develop a reliable 
estimate of uncollected dollars. VA also does not have a complete 
measure of its full collections costs. Consequently, VA cannot 
determine how effectively it supplements its medical care appropriation 
with third-party collections.

Mr. Chairman, this concludes my prepared remarks. I will be pleased to 
answer any questions you or other members of the subcommittee may have.

Contact and Acknowledgments:

For further information regarding this testimony, please contact 
Cynthia A. Bascetta at (202) 512-7101. Michael T. Blair, Jr. and 
Michael Tropauer also contributed to this statement.

[End of section]

Appendix I: 2001 Improvement Plan Status as of April 28, 2003:

[See PDF for image]

[A] Certain actions are mandated in the plan, that is, are required, 
but these actions are not legal or regulatory mandates.

[B] One action item was cancelled but its intended improvements will be 
incorporated into an automated financial system initiative.

[C] VA designated the electronic billing project, shown here as "17a," 
as completed. However, this indicated only partial completion of action 
17, which includes an additional project.


[End of figure]

[End of section]

Related GAO Products:

VA Health Care: Third Party Collections Rising as VA Continues to 
Address Problems in Its Collections Operations. GAO-03-145. Washington, 
D.C.: January 31, 2003.

VA Health Care: VA Has Not Sufficiently Explored Alternatives for 
Optimizing Third-Party Collections. GAO-01-1157T. Washington, D.C.: 
September 20, 2001.

VA Health Care: Third-Party Charges Based on Sound Methodology; 
Implementation Challenges Remain. GAO/HEHS-99-124. Washington, D.C.: 
June 11, 1999.

FOOTNOTES

[1] U.S. General Accounting Office, VA Health Care: VA Has Not 
Sufficiently Explored Alternatives for Optimizing Third-Party 
Collections, GAO-01-1157T (Washington, D.C.: Sept. 20, 2001).

[2] U.S. General Accounting Office, VA Health Care: Third Party 
Collections Rising as VA Continues to Address Problems in Its 
Collections Operations, GAO-03-145 (Washington, D.C.: Jan. 31, 2003).

[3] The management of VA's hospitals and other health care facilities 
is decentralized to 21 regional networks.

[4] The revenue manager in Network 9 (Nashville) said that coders were 
getting better at the manual searching that is required to find 
billable professional services and laboratory tests. During fiscal year 
2001, coders missed some billable care because of inadequate searches 
through the various sources of information used to document services 
and tests.

[5] T. Michael Kashner, Ph.D., J.D., et al., Final Report: Veterans 
Affairs Patient Health Insurance Survey (VAPHIS), a survey funded by 
the Department of Veterans Affairs, February 16, 2002. 

[6] Department of Veterans Affairs, Office of Inspector General, Audit 
of the Medical Care Collection Fund Program, Report No. 01-00046-65 
(Washington, D.C.: Feb. 26, 2002).

[7] Economic Systems, Inc. and AdvanceMed, Professional Fee Backlog 
Assistance: Final Technical Report, a report prepared for the 
Department of Veterans Affairs, March 5, 2002.

[8] In September 2002, the revenue manager anticipated that the backlog 
would be reduced to $2 million by the end of fiscal year 2002 because 
the medical centers had hired new coders and the network had created a 
central pool of seven coders.

[9] One action item was cancelled but its intended improvements will be 
incorporated into an automated financial system initiative.

[10] In the conference report accompanying its fiscal year 2002 
appropriation, VA was directed to begin a demonstration project of a 
patient financial services system installed and operated by a 
contractor. H.R. Conf. Rep. No. 107-272, at 56 (2001).