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entitled 'VA Health Care: Third-Party Collections Rising as VA 
Continues to Address Problems in Its Collections Operations' which was 
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Report to the Chairman, Subcommittee on Oversight and Investigations, 

Committee on Veterans’ Affairs, House of Representatives:



United States General Accounting Office:



GAO:



January 2003:



VA Health Care:



Third-Party Collections Rising as VA Continues to Address Problems in 

Its Collections Operations:



GAO-03-145:



GAO Highlights:



Highlights of GAO-03-145, a report to the Chairman, Subcommittee on 

Oversight and Investigations, Committee on Veterans’ Affairs, House 

of Representatives 



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 2001, GAO testified that problems in VA’s collections operations 

diminished VA’s collections.  For this report, GAO was asked to examine 

VA’s third-party collections and problems in collections operations for 

fiscal year 2002 as well as its initiatives to improve collections.



What GAO Found:



VA’s fiscal year 2002 third-party collections rose by 32 percent, 

continuing an upward trend that began in fiscal year 2001.  The 

increase 

in collections reflected VA’s improved ability to manage the larger 

billing volume and more itemized bills required under its new fee 

schedule.  Billings increased mainly due 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—according 

to VA managers in three regional health care networks.  However, VA 

continues to address operational problems, such as missed billing 

opportunities, that limit the amount VA collects.



To address operational problems and further increase collections, VA 
has 

several initiatives under way and is developing additional ones.  VA 
has 

been implementing initiatives in its 2001 improvement plan that was 

designed to address operational problems, such as unidentified 
insurance 

for some patients, insufficient documentation of services for billing, 

shortages of coding staff, and insufficient pursuit of accounts 

receivable. VA’s last formal status report in May 2002 designated only 
8 

of the plan’s 15 initiatives scheduled for completion by that time as 

having been completed.  VA continues implementation of this plan and 

is also developing new initiatives, such as an automated financial 

system to better serve billing needs.  It is too early to evaluate the 

extent to which VA’s full implementation of its 2001 plan and new 

initiatives will be able to address operational problems and further 

increase third-party collections.  In commenting on a draft of this 

report, VA generally agreed with our findings



VA’s Third-Party Collections, Fiscal Years 1997 through 2002



[See PDF for image]



[End of figure]



www.gao.gov/cgi-bin/getrpt?GAO-03-145. To view the full report, 

including the scope and methodology, click on the link above. For more 

information, contact Cynthia A. Bascetta at (202) 512-7101.



[End of section]



Contents:



Letter:



Results in Brief:



Background:



Collections Are Increasing, but Operational Problems Limit Insurance 

Payments:



VA Is Implementing Planned Actions and Developing Other Initiatives to 

Address Problems in Collections Operations:



Concluding Observations:



Agency Comments and Our Evaluation:



Appendix I: Scope and Methodology:



Appendix II: Comments from the Department of Veterans 

Affairs:



Table:



Table 1: Percentage Increases in Collections for Networks Selected for 

Study, October 2000 through February 2001 Compared to October 2001 

through February 2002:



Figures:



Figure 1: VA’s Third-Party Collections Processes:



Figure 2: VA’s Third-Party Collections, Fiscal Years 1997 through 2002:



Figure 3: Improvement Plan’s Actions Designated as Completed by VA, as 

of May 25, 2002:



Abbreviations:



HMO: health maintenance organization

PFSS: Patient Financial Services System

VA: Department of Veterans Affairs

VHA: Veterans Health Administration:



United States General Accounting Office:



Washington, DC 20548:



January 31, 2003:



The Honorable Steve Buyer

Chairman

Subcommittee on Oversight and Investigations

Committee on Veterans’ Affairs

House of Representatives:



Dear Mr. Chairman:



The Department of Veterans Affairs (VA) provides health care to 

eligible veterans and, under certain circumstances, VA is authorized to 

collect reasonable charges from their health insurers. Specifically, VA 

can bill insurers for treatment of conditions that are not a result of 

injuries or illnesses incurred or aggravated during military 

service.[Footnote 1] VA cannot bill for health care conditions that 

result from military service, nor is it generally authorized to collect 

from Medicare and Medicaid. In fiscal year 2002, VA collected $687 

million in insurance payments, which are known as third-party 

collections. These collections were VA’s largest source of revenue to 

supplement its $21 billion medical care appropriation, and they helped 

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 3.8 

million in fiscal year 2001, and VA predicts continuing growth in its 

patient workload.[Footnote 2]



Over the past several years, we and others have raised concerns about 

VA’s ability to maximize its third-party collections to enhance 

revenue. For example, a VA Inspector General report stated that VA 

missed billing opportunities, had billing backlogs, and did inadequate 

follow-up on accounts receivable in fiscal years 2000 and 

2001.[Footnote 3] 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 4]



At your request, we have examined VA’s progress with third-party 

collections since September 2001. In this report, we are providing an 

update on (1) VA’s third-party collections and problems in collections 

operations for fiscal year 2002 and (2) VA’s initiatives to improve 

collections. To conduct our review, we examined VA’s collections data 

for fiscal years 2001 and 2002; reviewed relevant VA documents, such as 

its 2001 collections improvement plan; and interviewed officials in VA 

headquarters and in 3 of VA’s 21 health care networks[Footnote 5]--

Network 2 (Albany), Network 9 (Nashville), and Network 22 (Long Beach)-

-to better understand the reasons for increased collections. Our work 

was performed from February 2002 through January 2003 in accordance 

with generally accepted government auditing standards. For more details 

on our scope and methodology, see appendix I.



Results in Brief:



VA’s third-party collections for fiscal year 2002 totaled $687 million, 

32 percent more than for fiscal year 2001. VA’s increased collections 

have resulted from VA’s submitting more insurance bills and receiving 

more payments than in the prior year. Billings increased mainly due 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--according to VA managers in three health care 

networks. Although VA reported improvements, 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.



To further improve collections, VA has several initiatives under way 

and is developing additional ones. In September 2001, VA produced its 

Veterans Health Administration Revenue Cycle Improvement Plan that 

included 24 actions to improve collections by addressing problems, such 

as unidentified insurance for some patients and gaps in the automated 

capture of billing data. However, VA’s last formal status report in May 

2002 designated only 8 of these actions as completed, although 15 were 

scheduled for completion by that time. The plan is scheduled for full 

implementation by the end of 2003. In May 2002 VA also established the 

Chief Business Office in its Veterans Health Administration (VHA) to 

direct VHA’s Revenue Office and to develop a new approach for VA’s 

collections activity. VA officials told us that the new approach will 

combine the improvement plan’s actions with additional initiatives, 

such as the development of an automated financial system that better 

serves billing needs. The new approach is also intended to establish 

additional performance measures and standards for oversight of 

collections units’ performance and to strengthen VA’s understanding of 

how to improve collections. However, it is too early to evaluate the 

extent to which VA will be able to address operational problems and 

further increase collections by fully implementing its 2001 plan and 

new approach.



In commenting on a draft of this report, VA generally agreed with our 

findings. VA suggested that our title should emphasize its effort to 

build infrastructure for effective collections operations rather than 

its continuing effort to address problems in collections operations. We 

believe that our title is accurate because VA continues to address 

problems that we and others have identified in VA’s collections 

operations.



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 veterans without service-connected 

disabilities or low incomes. VA expected that collections from third-

party payments, copayments, and deductibles would cover the majority of 

costs for higher-income veterans without service-connected 

disabilities. These veterans increased from about 4 percent of all 

veterans treated in fiscal year 1996 to about 20 percent in fiscal year 

2001.



To collect from health insurers, as shown in figure 1, 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 serves 

to create and send 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.



Figure 1: VA’s Third-Party Collections Processes:



[See PDF for image]



[End of figure]



In 1999, VA adopted a new fee schedule, called “reasonable charges,” 

which are itemized fees based on diagnoses and procedures, and the new 

schedule allows VA to bill in a way that more accurately captures the 

care provided. Previously, VA had nine charges for inpatient care and 

one charge for outpatient care. These charges were not specific to the 

care provided. For example, VA had charged the same per diem rate for 

any patient in a surgical bed section regardless of the care provided. 

In addition, before adopting the new fee schedule, VA had billed all 

outpatient visits, including surgery, based on VA’s average outpatient 

cost of $229, a single rate that had limited VA’s ability to collect 

higher amounts for more expensive care. In contrast, when the 

reasonable charges fee schedule was adopted in September 1999, an 

outpatient hernia surgery charge increased to about $6,500; and an 

office visit charge for an established patient decreased to a range of 

about $22 to $149, depending on the care given.[Footnote 6]



By linking charges to the care provided, VA created new bill-processing 

demands--particularly in the three areas of documenting care, coding 

that care, and processing bills per episode of care. First, VA must be 

prepared to provide an insurer supporting medical documentation for the 

itemized charges. Second, VA must accurately assign medical diagnoses 

and procedure codes to set appropriate charges, a task which requires 

coders to search through medical documentation and various databases to 

identify all billable care. Third, in contrast to a single bill for 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.



Collections Are Increasing, but Operational Problems Limit Insurance 

Payments:



For fiscal year 2002, VA collected third-party payments of $687 

million, a 32 percent increase over its fiscal year 2001 collections. 

The increased collections in fiscal year 2002 resulted from VA’s 

submitting and collecting for more bills than previously. According to 

three network revenue managers we interviewed, billings increased 

mainly because of a reduction of billing backlogs and improvements in 

the processes necessary to collect under the new reasonable charges fee 

schedule. Nevertheless, VA’s ability to collect was limited by problems 

such as missed billing opportunities. VA does not know how many dollars 

remain uncollected because of such limitations.



Third-Party Collections Increased:



For fiscal year 2002, VA collected $687 million, up 32 percent compared 

to the $521 million collected during fiscal year 2001. The increased 

collections reflected VA’s processing 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.



VA had difficulties establishing the collections processes to bill 

under a new fee schedule, processes which were necessary to achieve the 

increased billing and collections in fiscal year 2002. Although VA 

anticipated that the shift to reasonable charges would yield higher 

collections, collections dropped in fiscal year 2000 after implementing 

the new fee schedule in September 1999. 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 2, 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. According to VA, by the summer of 2000, facilities had 

sufficiently implemented processes to move forward with billing under 

reasonable charges. 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, over 8 million bills that constituted a 

54 percent increase over the number in fiscal year 2001.



Figure 2: VA’s Third-Party Collections, Fiscal Years 1997 through 2002:



[See PDF for image]



[End of figure]



VA officials cited various sources for an increased number of bills in 

fiscal year 2002. Managers we spoke with in three networks--Network 2 

(Albany), Network 9 (Nashville), and Network 22 (Long Beach)--mainly 

attributed the increased billing to reductions in billing backlogs. 

They also cited an increased number of patients with billable insurance 

as a factor for the increased billing. In addition, a May 2001 change 

in the reasonable-charges fee schedule for medical evaluations allowed 

billing for a facility charge in addition to billing for the 

professional service charges, a change that contributed to the higher 

volume of bills in fiscal year 2002.



Increased collections for fiscal year 2002 reflected VA’s improved 

ability to manage the volume and billing processes required to produce 

multiple bills under reasonable charges, according to three network 

revenue managers. 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 for billers. 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 coders were getting better at identifying all 

professional services that can be billed under reasonable 

charges.[Footnote 7] 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 productivity standards and a streamlining of their jobs to 

focus solely on billing.



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. 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 8] 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 9] Of that 

unbilled amount, 63 percent was estimated to be unbillable primarily 

because of insufficient documentation. In addition, the study found 

coders often missed services that should have been coded for billing.



According to the Director of the Revenue Office, 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. During 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 for fiscal year 2002, or 9 

percent.[Footnote 10] 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 was improving for billing, they 

reported a continuing need to improve physicians’ documentation. In 

addition, Network 22 (Long Beach) reported that accounts receivable 

staff had difficulties keeping up with the increased volume of bills 

because it had not hired additional staff or contracted help for 

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.[Footnote 11] Some 

uncollected dollars resulting from currently missed billing 

opportunities--such as billable care missed in coding--are not readily 

quantified. Other uncollected dollars--such as those from backlogged 

bills and uncollected accounts receivable--are either only partially 

quantifiable or their potential contribution to total collections is 

uncertain. For example, even though the uncollected dollars in older 

accounts receivable can be totaled, the yield in payments through more 

aggressive pursuit of accounts receivable is uncertain. This is 

because, according to VA officials, some portion of the billed dollars 

is not collectable due to VA inappropriately billing for services not 

covered by the insurance policy, billing against a terminated policy, 

or not closing out the accounts receivable after an insurer paid the 

bill.[Footnote 12]



VA Is Implementing Planned Actions and Developing Other Initiatives to 

Address Problems in Collections Operations:



VA continues to implement its 2001 improvement plan and is planning 

more improvements. Although the improvement plan could potentially 

improve operations and increase collections, it is not scheduled for 

full implementation until December 2003. In May 2002, VA created a new 

office in VHA, the Chief Business Office, in part to address 

collections issues. According to VA officials, this office is 

developing a new approach to improvements, which will include 

initiatives beyond those in the improvement plan.



2001 Plan to Improve Collections Is Partially Implemented:



VA’s improvement plan was designed to increase collections by improving 

and standardizing its 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, shortages of coding staff, gaps 

in the automated capture of billing data, insufficient pursuit of 

accounts receivable, and uneven performance across collections 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 to provide coders better access to documentation and legible 

records.



When fully implemented, the plan’s actions can improve collections to 

the extent that they can reduce operational problems such as missed 

billing opportunities. For example, two of the plan’s actions--

requiring patient contacts prior to scheduled appointments to gather 

insurance information and electronically linking VA to major insurers 

to identify patients’ insurance--are intended to increase the number of 

patients identified with insurance. A recent study 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 

13] This finding suggests that VA could have billed for 30 percent more 

patients than it actually billed.



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 shown in figure 

3, VA had designated only 8 as completed, as of the last formal status 

report on the plan in May 2002.[Footnote 14]



Figure 3: Improvement Plan’s Actions Designated as Completed by VA, as 

of May 25, 2002:



[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] 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]



Some of the plan’s actions that VA has designated as completed needed 

additional work. For example, although VA designated electronic billing 

as completed in the May 2002 report, in August 2002 a VA official 

indicated that 20 hospitals were still working on a step required to 

transmit bills to all payers. In other cases, VA has designated an 

action completed by mandating it in a memorandum or directive. However, 

mandating an action in the past has not necessarily ensured its full 

implementation. For example, although an earlier 1998 directive 

required patient preregistration, the 2001 improvement plan reported 

that preregistration was not implemented consistently across VA and 

thus mandated its use.[Footnote 15]



VA Is Developing Other Improvement Initiatives:



Officials in VHA’s new Chief Business Office told us that this office 

is developing a new approach for improving third-party collections. 

According to the Chief Business Officer, the Under Secretary of Health 

proposed, and the Secretary approved, the establishment of the Chief 

Business Office to underscore the importance of revenue, patient 

eligibility, and enrollment functions; and to give strategic focus to 

improving these functions. He said the new approach can help increase 

revenue collections by further revising processes and providing a new 

business focus on collections.



Officials in this office told us that the new approach will combine 

these and other actions with the actions in the improvement plan. For 

example, the Chief Business Office’s improvement strategy incorporates 

electronic transmission of bills and of third-party payments, which are 

part of the 2001 improvement plan. The new approach also encompasses 

initiatives beyond the improvement plan, such as the one in the Under 

Secretary of 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, this initiative has shown some sign 

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.



Another initiative in the new approach is the Patient Financial 

Services System (PFSS). PFSS is an automated financial system focused 

on patient accounts, which is intended to overcome operational problems 

in VA’s current automated billing system. For example, VA’s automated 

system for clinical information was not designed to provide all of the 

episode-of-care information, such as the health care provider and 

diagnoses, that are required for billing. The development of PFSS is 

tied to a demonstration project of a financial system, which is now 

being designed for Network 10 (Cincinnati).[Footnote 16] According to 

the Deputy Chief Business Officer, VA anticipates awarding a PFSS 

contract by April 1, 2003. The Chief Business Office’s plan is to 

install this financial system in other facilities and networks if it is 

successfully implemented in the Network 10 (Cincinnati) demonstration.



The Chief Business Office also intends to improve collections by 

developing better performance measures, which will be similar to those 

used in the private sector.[Footnote 17] For example, the office 

intends to use the measure of gross days revenue outstanding, which 

indicates the pace of collections relative to the amount of accounts 

receivable. During fiscal year 2003, the office plans to hold network 

and facility directors accountable for collections through standards 

that are tied to these performance measures. In addition, the Chief 

Business Officer said that tracking performance with these measures 

could help identify further opportunities for collections improvements.



The Chief Business Office is developing the new initiatives, which it 

had not formalized into a planning document as of August 2002. Certain 

key decisions were under consideration. For example, the Chief Business 

Officer was considering whether to centralize some processes at the 

network or national level and was developing the performance standards 

that would be required for holding network and facility directors 

accountable. Moreover, according to the Chief Business Officer, 

implementing PFSS will require the office to resolve some issues, 

including making its existing systems provide sufficient data to 

support the new financial system.



Concluding Observations:



As VA faces increased demand for medical care, third-party collections 

for nonservice-connected conditions remain an important source of 

alternative revenue to supplement VA’s resources. Our work and VA’s 

continuing initiatives to improve collections suggest that VA could 

collect additional supplemental revenues because it has not collected 

all third-party payments that it could in fiscal year 2002. However, VA 

does not have an estimate of the amount of uncollected dollars, which 

it needs to assess the effectiveness of its current processes.



VA has been improving its billing and collecting under the new fee 

schedule established in 1999, but VA has not completed its efforts to 

address problems in collections operations. In this regard, fully 

implementing VA’s 2001 improvement plan could help VA maximize future 

collections by addressing problems such as missed billing 

opportunities. However, the plan’s reliance on directives, in some 

cases, to achieve increased collections is not enough to ensure full 

implementation and optimal performance. The Chief Business Office’s new 

approach could also enhance collections. VA’s new Chief Business 

Office’s challenge is to ensure such performance 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. However, it is too early to evaluate the extent 

to which VA will be able to address operational problems and further 

increase collections by fully implementing its 2001 plan and new 

approach.



Agency Comments and Our Evaluation:



The Department of Veterans Affairs provided written comments on a draft 

of this report, which are found in appendix II. VA generally agreed 

with our findings that it continues to make improvements in increased 

collections and VHA’s Business Office is developing new initiatives to 

further enhance collections. In addition, VA clarified that it may, 

under limited circumstances, collect from Medicare although generally 

it may not do so. We changed our report accordingly.



VA also suggested that our title was misleading because it stated that 

VA continues to address problems in its collections operations rather 

than stating that VA is building infrastructure to implement effective 

collections operations. We believe that our title is accurate because 

VA continues to address problems that we and others have identified in 

VA’s collections operations. VA has acknowledged such problems in the 

past, including unidentified insurance for some patients, insufficient 

documentation for billing, and shortages of coding staff. VA continues 

to implement the 2001 improvement plan that it developed to address 

these and other problems. VA’s new initiatives also address problems, 

such as gaps in automated capture of billing data, that have been 

previously identified.



As arranged with your office, unless you release its contents earlier, 

we plan no further distribution of this report until 30 days after its 

issuance date. At that time, we will send copies of this report to the 

Secretary of Veterans Affairs, interested congressional committees, and 

other interested parties. We will also make copies available to others 

upon request. In addition, this report will be available at no charge 

on GAO’s Web site at http://www.gao.gov.



If you or your staff have any questions about this report, please call 

me at (202) 512-7101. James Musselwhite and Terry Hanford also 

contributed to this report.



Sincerely yours,



Cynthia A. Bascetta

Director, Health Care--Veterans’ Health and Benefits Issues:



Signed by Cynthia A. Bascetta



[End of section]



Appendix I: Scope and Methodology:



To assess the Department of Veterans Affairs’ (VA’s) progress with 

collections in fiscal year 2002, we obtained and examined data on VA’s 

third-party bills and collections. We also interviewed officials in VA 

headquarters and in three VA health care networks to understand the 

reasons for the increased collections compared to fiscal year 2001 as 

well as any operational problems. To provide information on VA’s 2001 

improvement plan and its emerging new approach to improvements, we 

reviewed relevant VA documents and interviewed VA officials.



We conducted interviews from April through June 2002 with managers in 

three networks concerning collections.[Footnote 18] In addition, we 

gathered data on third-party bills and collections for fiscal years 

2001 and 2002. Our review of the improvement plan’s implementation 

started with its completion status in March 2002 and ended with its 

status through May 2002, which was the date of VA’s last formal report 

on the plan’s status. An official in the Chief Business Office told us 

in September 2002 that a new status report for the 2001 plan was 

planned but not yet available. During August through October 2002, we 

gathered information from officials in the Chief Business Office about 

additional improvement initiatives.



To better understand the increased collections in fiscal year 2002 and 

any limitations to those collections, we judgmentally selected three 

networks for more detailed study. These networks provided different 

examples of above-and below-average growth in collections, considered 

separately for inpatient care and outpatient care. (See table 1.) Based 

on available data at the time of selection, Network 9 (Nashville) had 

above-average collections increases for both inpatient care and 

outpatient care bills. Network 2 (Albany) exceeded average collections 

increases for only outpatient care bills, whereas Network 22 (Long 

Beach) had above-average collections increases for only inpatient care 

bills.



Table 1: Percentage Increases in Collections for Networks Selected for 

Study, October 2000 through February 2001 Compared to October 2001 

through February 2002:



Systemwide averages; Collections: Inpatient care: Percentage increase: 

20; Collections: Inpatient care: Relation to average: Not applicable; 

Collections: Outpatient care: Percentage increase: 54; Collections: 

Outpatient care: Relation to average: Not applicable; Collections: 

Total: Percentage increase: 35; Collections: Total: Relation to 

average: Not applicable.



Network 2 (Albany); Collections: Inpatient care: Percentage increase: 

3; Collections: Inpatient care: Relation to average: Below; 

Collections: Outpatient care: Percentage increase: 79; Collections: 

Outpatient care: Relation to average: Above; Collections: Total: 

Percentage increase: 32; Collections: Total: Relation to average: 

Below.



Network 9 (Nashville); Collections: Inpatient care: Percentage 

increase: 43; Collections: Inpatient care: Relation to average: Above; 

Collections: Outpatient care: Percentage increase: 102; Collections: 

Outpatient care: Relation to average: Above; Collections: Total: 

Percentage increase: 71; Collections: Total: Relation to average: 

Above.



Network 22 (Long Beach); Collections: Inpatient care: Percentage 

increase: 60; Collections: Inpatient care: Relation to average: Above; 

Collections: Outpatient care: Percentage increase: 34; Collections: 

Outpatient care: Relation to average: Below; Collections: Total: 

Percentage increase: 50; Collections: Total: Relation to average: 

Above.





Source: VA Monthly Revenue Office Report: February 2002 Data.



[End of table]



Although we did not verify VA data on collections and bills, we used 

the data reported by VA’s Revenue Office in its analyses of third-party 

collections. The data source is VA’s Veterans Health Information 

Systems and Technology Architecture National Database. This database 

includes data for collections from various sources--including third-

party payments, patient copayments, and proceeds from sharing 

agreements in which VA sells services to the Department of Defense and 

other providers.



[End of section]



Appendix II: Comments from the Department of Veterans Affairs:



THE SECRETARY OF VETERANS AFFAIRS, WASHINGTON:



December 23, 2002:



Ms. Cynthia A. Bascetta Director, Health Care-Veterans’ Health and 

Benefits Issues:



U. S. General Accounting Office 441 G Street, NW Washington, DC 20548:



Dear Ms. Bascetta:



The Department of Veterans Affairs (VA) has reviewed your draft report, 

VA HEALTH CARE: Third-Party Collections Rising as VA Continues to 

Address Problems in the Collections Operations (GAO-03-145). As the 

General Accounting Office (GAO) acknowledged, the Veterans Health 

Administration (VHA) continues to make improvements in increased 

collections. As GAO reports, VHA’s Business Office is developing new 

initiatives that will further enhance collections. VA suggests that the 

title is somewhat misleading. Rather than addressing problems in 

collections operations, VA has actively engaged in building the basic 

infrastructure (effective management oversight, personnel, information 

technology systems, processes, etc.) needed to implement and sustain 

effective collection operations.



VA has one suggested edit to page 1 of the report, third sentence, 

which states: “VA cannot bill for health care conditions that result 

from military service, nor is it authorized to collect from Medicare or 

Medicaid for any conditions.” Currently, there are at least two 

situations in which VA may be reimbursed by the Medicare program: 1) 

treatment for end-stage renal disease and 2) when VA treats someone 

believed to be eligible for VA medical care, but turns out to be 

ineligible for VA care, but covered by Medicare. It is recommended that 

the word “generally” be inserted before “authorized.”:



Thank you for the opportunity to comment on your draft report.



Sincerely yours,



Anthony J. Principi



Signed by Anthony J. Principi



[End of section]



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FOOTNOTES



[1] VA cannot collect payments from certain insurers. For example, VA 

cannot collect payments from health maintenance organizations (HMOs) 

when VA is not a participating provider.



[2] According to VA’s estimate, there were about 25 million veterans in 

2001.



[3] VA Office of Inspector General, Audit of the Medical Care 

Collection Fund Program, Report No. 01-00046-65 (Washington, D.C.: Feb. 

26, 2002).



[4] 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).



[5] The management of VA’s hospitals and other health care facilities 

is decentralized to 21 regional networks.



[6] These amounts reflected the national average charges in September 

1999 for the services specified. To reflect the amounts charged by 

other local providers, the charges that VA actually bills vary by the 

locality in which VA services are provided.



[7] 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 that document services and 

tests.



[8] VA Office of Inspector General, Report No. 01-00046-65.



[9] Economic Systems, Inc. and AdvanceMed, Professional Fee Backlog 

Assistance: Final Technical Report, a report prepared for the 

Department of Veterans Affairs, March 5, 2002.



[10] 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.



[11] In addition, VA does not know the net impact of actual third-party 

collections on supplementing its annual appropriation for medical care. 

This is because, according to VA officials, VA does not have a way to 

routinely capture its full collections costs.



[12] VA’s accounts receivable totals are larger than what is 

collectible, in part, because VA includes the entire amount of charges 

for veterans covered by Medicare, when those veterans have Medicare 

supplemental insurance. Although VA cannot generally collect from 

Medicare, it includes the total as part of its billing process to the 

supplemental insurers to determine the proportion of charges the 

supplemental insurers will pay.



[13] 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. The Chief 

Business Officer told us that his office plans to do another survey to 

confirm its results.



[14] A Chief Business Office official stated in September 2002 that the 

office plans to develop a status report that includes the improvement 

plan as well as other actions in its new approach.



[15] VA issued a 2002 directive to reemphasize the administrative 

mandate.



[16] In the conference report accompanying its fiscal year 2002 

appropriation, VA was directed to begin a demonstration project of a 

contractor-installed and operated patient financial services system. 

H.R. Conf. Rep. No. 107-272, at 56 (2001).



[17] As we noted in our 2001 testimony, VA’s performance does not 

compare favorably to some industry benchmarks, such as the number of 

days required to bill. However, comparisons between VA and the private 

sector should take into account how VA’s processes differ from those in 

the private sector. For instance, VA has the additional step of 

determining whether the care is service-connected, and VA bills for 

both facility and physician charges whereas private sector hospitals 

may only bill for facility charges. To make comparisons with industry 

benchmarks more relevant, VA is considering adjustments to its new 

measures.



[18] We spoke with revenue managers in the three networks. At the 

suggestion of the revenue manager in Network 22 (Long Beach), we also 

spoke with the facility’s business manager, who headed the network’s 

collections committee. Moreover, we had limited follow-up discussions 

during September 2002 with the Network 9 (Nashville) revenue manager.



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analyses, recommendations, and other assistance to help Congress make 

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