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Jenna Tropea

Jenna Tropea

As a long-time writer and content marketer, Jenna Tropea covers a wide range of topics from patient engagement to healthcare policy and regulations. Jenna received her MBA from Clemson University and currently serves as Online Marketing Strategist to ImagineSoftware. 

You can contact Jenna via email at

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MIPS 2019: What You Should Know for Successful Reporting

On November 1, 2018, the Centers for Medicare and Medicaid Services (CMS) released its 2019 Quality Payment Program (QPP) Final Rule, which includes changes made to the Merit-Based Incentive Payment System (MIPS).  The 2,378-page document details major changes to how CMS plans to continue implementation of its two payment tracks to promote interoperability, reduce clinician and administrative burden, implement meaningful measures, and improve patient outcomes.  Let’s look at some key rules and regulations you should know about the program in its third year to have the most successful reporting period possible. 

Participation Changes

CMS estimates that 798,000 clinicians will be eligible to participate in MIPS for the 2019 performance period, up by almost 150,000 from the estimate provided in the proposed rule.  This drastic jump in participation is mainly due to these new participation rules:

New eligible clinician types - CMS has added a list of clinician types that can now earn a positive payment adjustment. Those are:

  • Physical Therapists
  • Occupational Therapists
  • Speech-Language Pathologists
  • Audiologists
  • Clinical Psychologists
  • Registered Dieticians or Nutrition professionals 

    New low-volume threshold participation - The updates made low-volume 
    threshold participation have allowed much more flexibility for both parties: clinicians who want to report, and those who barely participate in Medicare and may feel burdened. 

    Part I of this new rule is a third low-volume threshold.  Previously, clinicians were excluded from MIPS if they had $90,000 or less in Part B allowed charges for covered professional services or provided care for 200 or fewer Part B beneficiaries.  In addition, the 2019 Final Rule has added clinicians who provide 200 or less covered professional services paid under the 2019 Medicare Physician Fee Schedule (PFS) rule to be excluded from MIPS.

    Part II is focused on more inclusion.  Eligible clinicians who meet or exceed one or two of the exclusion thresholds can opt-in to MIPS for the 2019 reporting period.  In addition, clinicians can choose to participate even if they are excluded from the program based on the low-volume threshold.  This allows more providers to take advantage of the positive payment adjustment.
    Performance Updates

    Performance adjustments rise to 7% - For the 2019 reporting year, eligible clinicians can receive a positive or negative payment adjustment of up to 7% for 2021 Medicare reimbursement, as opposed to the 5% in 2018 and 4% in 2017. Depending on how much a practice bills for Medicare each year, this could amount to bringing in or losing hundreds of thousands of dollars. The exact amount of adjustment can vary depending on the number of providers in the bonus and penalty pools, but CMS plans to distribute a larger amount of incentives for 2019 compared to 2018 – approximately $390 million.

    Performance and Exceptional Performance thresholds - In the Final 2019 rule, CMS doubled the MIPS performance threshold from 15 to 30 points.  If you have the right resources, this may be a relatively easy task.  However, missing the threshold could mean up to a 7% negative payment adjustment for Medicare reimbursement.  The performance threshold is projected to increase by 15 points each year until 2022, so it’s important that you have the right partners and resources in place to keep track of your data.

    The exceptional performance threshold also increased for 2019 MIPS participants.  To be eligible for the $500 million exceptional performance bonus pool (which is separate from the $390 million performance pool), providers must score a minimum of 75 points, as opposed to the 70 points from 2018.  Though it’s a small increase, this change is projected to reduce the number of participants that qualify, which translates to better reimbursement for those that meet or exceed the threshold.

    Category Weight Changes - For 2019, the Quality category will go down to 45 points from 50 points and the Cost category will increase 5 points to 15.  Meanwhile, Improvement Activities (15 points) and Promoting Interoperability (25 points) remain the same. 

    Quality Measures Modified - For 2019, CMS removed 26 MIPS quality measures including some specialty-specific measures including Dermatology, Otolaryngology, and Ophthalmology.  The removal of these measures was done in part to move towards outcome-based measures and away from process-based and topped-out measures.  Topped-out measures are those in which average scores are so high that it’s difficult for CMS to meaningfully rank providers.  This makes the Quality category more difficult for clinicians but aligns with CMS’s goal to make MIPS more challenging.  New measures were added including four patient reported outcome measures, six high priority measures, and two measures on clinical topics in the Meaningful Measures framework.  The small practice bonus is increasing to 6 points in the numerator for the Quality performance score instead of a standalone bonus.  This is for clinicians in small practices who submit at least one measure, either individually or as a group or virtual group.  With so many changes taking place, it’s important to partner with a technology vendor that stays on top of these reporting adjustments for you.

    Promoting Interoperability Overhaul
    CMS has made several large changes to the Promoting Interoperability (PI) category in efforts to foster meaningful data exchange and access among providers and patients. First, almost all 2018 measures were eliminated or modified and replaced with a new scoring methodology based solely on performance. All measures under this category now fall under one of four areas:

  • E-Prescribing
  • Health Information Exchange
  • Provider to Patient Exchange
  • Public Health and Clinical Data Exchange

    Unless a clinician or or group claims an exclusion, all are required to report certain measures from each objective.  Each area will be scored based on clinician performance.  Two new measures have been added to the e-Prescribing objective: Query of Prescription Drug Monitoring Program (PDMP) and Verify Opioid Treatment Agreement as optional with bonus points available. 
    New Cost Performance Measures - CMS has added eight new episode-based measures:
      1. Elective Outpatient Percutaneous Coronary Intervention (Procedural)
      2. Knee Arthroplasty (Procedural)
      3. Revascularization for Lower Extremity Chronic Critical Limb Ischemia (Procedural)
      4. Routine Cataract Removal with Intraocular Lens Implantation (Procedural)
      5. Screening/Surveillance Colonoscopy (Procedural)
      6. Intracranial Hemorrhage or Cerebral Infarction (Acute inpatient medical condition)
      7. Simple Pneumonia with Hospitalization (Acute inpatient medical condition)
      8. ST-Elevation Myocardial Infarction with Percutaneous Coronary Intervention (Acute inpatient medical condition)

      Reporting and Submission

      The 2015 Edition CEHRT is mandatory for 2019.  If you haven't upgraded already, you can still do so through mid-2019.

      CMS finalized 3 new submission terms: Collection Type, Submitter Type and Submission Type. Collection type refers to a set of quality measures with comparable specifications and data completeness criteria eCQMs, MIPS CQMs (formerly Registry Measures), QCDR measures, Medicare Part B claims measures, CMS Web Interface measures, the CAHPS for MIPS survey measure, and administrative claims measures. Submitter type refers to the MIPS eligible clinician, group, or third-party acting on behalf of the clinician or group that submits data. Submission type is how the data is submitted whether direct, upload, Medicare Part B claims or the CMS Web Interface.

      Facility-Based Reporting – CMS finalized facility-based reporting for 2019 performance period. A clinician qualifies for facility-based reporting if the individual furnishes 75% or more of their covered professional services in an inpatient hospital, on-campus outpatient hospital, or an emergency room, with at least a single claim billed for the inpatient hospital or emergency room. A group qualifies for facility-based reporting if 75% or more of the clinicians’ National Provider Identifiers (NIPs) billing under the Taxpayer Identification Number (TIN) are eligible for facility-based measurement as individuals. Facility-based measurement will be automatically applied to eligible clinicians and groups who have a higher quality and cost score compared to their regular MIPS quality and cost submission.

      A Successful Reporting Period

      While the 2019 Reporting Period may be the most challenging to date, CMS continues to assist clinicians, groups and virtual groups participate to the best of their abilities. To learn more about these services, visit the Quality Payment Program website here. To learn more the changes listed above, visit the CMS website here. For information on technology, education and support through our Registry partner Alpha II, visit our website here


    ImagineSoftware Acquires RCM Software Company ProviderAlly

    Charlotte, N.C. | March 12, 2019 -- Leading Revenue Cycle Management SaaS Platform ImagineSoftware announced today the acquisition of ProviderAlly, a provider of payment reconciliation services and related capabilities to the healthcare RCM space.  The addition of ProviderAlly adds a powerful technology to ImagineSoftware’s strong existing service offering and will further help clients optimize billing and collections workstreams.  The transaction marks ImagineSoftware’s first acquisition since partnering with Mountaingate Capital in April 2018.

    ProviderAlly provides a compelling and comprehensive financial data picture in the healthcare industry, bridging the divide between banking and practice management systems and allowing clients to understand payments in their organization while validating every dollar to the deposited funds.

    "We are very excited to welcome ProviderAlly into the Imagine family,” said Sam Khashman, CEO of ImagineSoftware.  “Wayne [Koch, CEO of ProviderAlly], is an accomplished technologist in the revenue cycle management space and brings invaluable experience to our leadership team.  We have tremendous conviction around our ability to leverage our combined capabilities and provide our customers an even better solution.”

    ImagineSoftware's mission is to provide industry-leading billing automation software and revenue cycle management applications.  With ProviderAlly joining the platform, the combined entity can offer its suite of products and services to an expansive list of clients.  Both companies take pride in being at the forefront of industry innovation to help clients improve financial efficiency.

    "By joining forces with Imagine, we gain vast industry experience and rapid scalability that will enable us to meet our clients’ evolving needs and continue to grow,” said Wayne Koch.  “We are excited about our partnership and the many opportunities that we can now pursue.”

    ImagineSoftware is the leading provider of medical billing automation software and revenue cycle management applications.  Offering powerful technology solutions for medical billing offices, practices, and hospitals, ImagineSoftware currently serves more than 46,000 physicians.  ImagineSoftware solutions improve financial efficiency, build provider reputation, and ultimately improve the patient experience.  For more information, visit and follow us on Twitter @ImagineTeam.

    For more information please contact:
    Elizabeth Suppa
    This email address is being protected from spambots. You need JavaScript enabled to view it.
    (704) 553-1004

    3 Tips to Negotiate Payer Contracts Like A Pro

    How well do you know your payer contracts? Understanding their terms and requirements are crucial to maximum reimbursement, but that’s no easy task. Confusing legal language and lengthy agreements are more than enough to cause discomfort and even reluctance to really delve deep into what each contract entails. However, you don’t have to be a lawyer to successfully manage your payer contracts. Here are a few tips that will help you negotiate your payer contracts like a pro, in ways that will ensure that you’re operating a smooth revenue cycle.
    • Know your terms
    • Monitor changes with reporting
    • Create a payer matrix
    From billing to reporting and analytics, we're your partner in creating a sustainable and more profitable practice.
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    Know Your Terms
    Medical Necessity - Your payers will only reimburse you for services they deem medically necessary to the patient. The definition can vary by payer. For example, for Medicare and Medicaid, the National Coverage Determinations and Local Coverage Determinations limit how often a provider can deliver a medically necessary service within a certain period. It’s important to know each of your payers’ definitions because billing for a service that is deemed medically unnecessary can result in fraud.

    "Lesser of" - This phrase helps payers ensure that they can reimburse at a rate that’s favorable to them. According to an article by MGMA, this type of language could mean that you’re shooting yourself in the foot in terms of reimbursement. A contract may call for a lesser contract rate, a certain percent of billed charges or a determined percentage of a state fee schedule. If a proposed agreement includes this language, verify your state schedules against an existing contract rate and that your chargemaster is set high enough above the contract rates to ensure enough reimbursement.

    Termination Provisions - Understanding the termination information in payer contracts will ensure that you’re not wasting resources on contracts that aren’t beneficial to your organization. The contract’s period, under what circumstances you or the payer can terminate, and termination duties should all be very clearly defined. Sometimes, a contract’s period will renew unless one party initiates termination or takes some other action. It’s important to be aware of termination language and receive regular updates on provisions so that it stays on your radar.

    Network Requirements - These will become more and more important as healthcare shifts towards value-based care. There is always language in contracts that states the credentialing criteria needed to join a network, but some contracts include language that allows payers to pick and choose physicians within an organization for the network. Be sure to specify whether this is the case in your current or future contracts. Network changes should be tied to credentialing criteria only.

    Fee Schedule - Your fee schedule determines how much your organization is paid for services and allows your front office billing staff to calculate co-insurance and deductibles for patients who are paying at time-of-service. It will also help determine whether your payers are paying you at the agreed upon rate and if you’re charging enough for services. If a payer always pays the claim in full, consider raising your rates. Physician’s Practice encourages charging 20-30% more than your payer’s reimbursement rate. We will go into more detail on how to better track your fee schedule in the reporting section of this post.

    Dispute Resolution - In the event of a claim denial or dispute, the dispute resolution policies in a contract outline how you should resolve the claim to recoup the revenue owed. According to the American Medical Association (AMA), providers should forego any language in a contract that legally binds providers to a specific dispute resolution process. The industry group goes into more detail: “Often the aggrieved party may need the leverage of litigation to get to a resolution of a dispute,” the group states. “In contractual disagreements between physicians and payers, the aggrieved party is often the physician, and the absence of language stating that these provisions are binding may give some wiggle room for this leverage. This isn’t the place, therefore, to argue for hardnosed language.”

    Monitor Changes with Reporting
    The easiest way to manage your payer contracts and keep tabs on who’s paying what is through reporting. Whether your organization has its own reporting, or if you’re a practice that outsources to a billing company, consider these reports that many RCM leaders use to track their reimbursement rates. If you’re not tracking these metrics or unsure if they’re available to you, consult your software vendor or billing company for more information. Your payers will have their own metrics to negotiate contracts, you should too.

    Charge Period Revenue Analysis - How long does it take to collect on charges? This report will show you if there are issues getting paid and whether you should reconsider payer contracts.

    Cash Flow Predictions - This will show how payers have paid you in the past and how you can expect to be paid in the future.

    Profile Exceptions - This helps you track if payers are paying you on the agreed upon rate, and whether you should reconsider contracts.

    Procedure Reimbursement - Are your payers paying you at the same rate, a better rate, or worse compared to last year? This dashboard will help you determine if you should negotiate with payers in the future.

    Receiving these reports on a daily, weekly or monthly basis will improve your ability to monitor payers and quickly respond to changes in a timely manner.

    Create a Payer Matrix
    Without a comprehensive list of your payer information readily available, it will be incredibly difficult to keep track of how you’re being paid. A payer matrix is a resource that holds all the key information you need from each contract – Reimbursement rates, billing guidelines, insurance verifications, contact information, etc. This tool acts as a database for the billing team to understand each contract and can serve as the foundation of your reporting. It’s also a very powerful tool for onboarding and training new employees. Here are a few steps you can take to start creating your payer matrix:

    Create the outline
    Consider the following sections as a starting point for your payer matrix:
    • Basic need-to-know information - Health plan names, types (Medicare, Medicaid, etc.), contracting representative, etc.
    • Areas of concern - What are your payers' medical necessity definitions? What are their definitions of clean claims?
    • Important dates and times - Effective date of contract, length of contract, termination dates, etc.
    • Deadlines - Timely filling deadlines, amendment provisions (including period in which the provider can respond), underpayment and overpayment recovery deadlines, etc.
    • Practice volume percentage
    • Preauthorization requirements
      Organize your data
      The most common platforms used to create payer matrixes are Excel and Access. Some providers invest in documentation management software. Consider how many employees will have access to the matrix and how many people may view it at the same time. Functionality of your matrix will be increasingly important as you give more employees access. Be sure to edit privacy settings and password protect the matrix if need be, so that no unauthorized changes are made.

      Documentation, distribution and training
      Before distributing your matrix, develop documentation on how to view, use and request edits to the payer matrix. This will be helpful when onboarding new employees and when updates need to be made. There is a myriad of reasons the matrix will need updating on a regular basis, so it’s important that employees with access and permission to edit the matrix have a defined process to follow to ensure information accuracy. Store the matrix in a centralized location for easy accessibility and develop short training sessions for new and current employees to stay abreast of what processes should be followed to use the matrix.

      How To Tackle The Top Revenue Cycle Management Challenges of 2019

      2019 will undoubtedly be an eventful one for healthcare, but it won't come without its challenges. Every new idea, technology and innovation present new risks that providers must face, both financially and at an organizational level. A new report by Crowe shows the top risk areas in revenue cycle management in healthcare this year. In this blog post, we will explore those challenges and address how to tackle each one in ways that are beneficial to your employees, patients and bottom line.

      Arm your business with efficiency through every step of the revenue cycle.
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      Billing and Collections - The Challenge

      Because there are so many moving parts throughout the billing and collections processes, the smallest inefficiency can lead to costly rework, denials and lost reimbursement.  Many providers look to outsourced billing to handle these functions, but even then, oversight of third-party vendor relationships must be managed to ensure operational and financial success.  According to Crowe, the major risks relating to this area include completeness and accuracy of billing, lost revenue, inadequate denials management and lack of third-party control visibility.

      Billing and Collections - The Solution

      • Use an analytics tool to track key performance indicators and areas for improvement - Tracking key performance indicators (KPIs) plays a large part in tracking the financial health of your business, both operationally and financially. KPIs help physicians and management understand the strengths and weaknesses of their revenue cycle to help guide future decisions. They also help prioritize resources and help recognize key success drivers. These 8 medical billing KPIs are a great starting point for organizations looking for quality KPIs that heavily impact financial performance. To make sense of this data, using a business intelligence reporting and analytics tool will improve your ability to identify trends and patterns, as well as increase awareness around what variables impact your practice.
      • Automate patient registration - Collecting accurate accurate patient information upfront sets the groundwork for efficient billing. Without it, denied claims and lost reimbursement typically follow. Each unique visit should be validated by staff under the patient billing system and the patient’s demographic information and insurance eligibility should be determined upfront. This can be done manually, but it’s laborious, time intensive and leaves room for human error. Supplement staff workflow with as much automation as possible to improve billing registration accuracy. Software solutions like ImagineAI validate when a patient is eligible for primary insurance listed on the visit and/or your list of top payors before the claim is sent to insurance. Once you receive the positive eligibility response, the AI solution will add a note to the visit with the patient’s identified payment information.
      • Communicate clearly with patients - Never underestimate the importance of being transparent. It’s necessary for providers to train their billing staff to answer questions about pricing over the phone and in person. Billing staff must learn that communication with patients is not a “soft skill” but something that must become second-nature. This is especially crucial during time of service, when staff is face to face with patients and must think on their feet.  Explain financial policies right away, follow up with the patient if there is any confusion and be sure to use an appropriate tone. It’s something that can easily be overlooked, but how you engage in conversation with a patient is just as important as what you say.
      • Third Party Visibility - Outsourcing parts of the revenue cycle process has its benefits, but lack of visibility can lead to micromanagement, which defeats the purpose of outsourcing. Medical billing companies and other third-party vendors should be able to supply you with performance reports automatically or upon request. This will give you much more visibility into your billing operations.  Most vendors will provide it even if it’s not automated.  Some go a step further and provide ad hoc or customized reports to their clients, you need only ask.

      Charge Capture - The Challenge

      Managing charge capture and maintaining an accurate charge description master (CDM) serve as the starting point for billing patients and payers and form the heart of a healthy billing cycle. Providers must accurately load and regularly update pricing for services while also billing in accordance with the charging and billing guidance provided by Medicare and other payers. Without the correct training on documentation and metrics put in place, the accuracy and completeness of charges becomes a major risk.

      Charge Capture - The Solution

      Hopefully, your medical billing software automatically flags incomplete charges.  Aside from that, there are several strategies that providers can adopt to ensure that charge capture is accurate and complete.

      • Proper training - Educate staff on existing rules and regulations including payer-specific rules, CMS rules, and your current procedural terminology codes. These change frequently so it’s important that employees are continually trained to ensure charge accuracy.
      • Work with what you have - Before jumping the gun and implementing new policies, leverage what you already have.  Use your EMR to identify missing and inaccurate charges and alert your team. Try setting up work queues to flag patterns of missing charges and high-quantity errors.
      • Review lag times - It’s good practice to review both lag times for date of service to billing/coding and from service date to posting date and claim submission. Compare to industry benchmarks to identify areas for improvement. Build the billing team and physician relationship - Improving charge accuracy can’t be accomplished by just the billing team alone. Establishing a strong relationship between the team and physicians will ensure more collaboration to correct the process in a way that’s mutually beneficial for both teams.
      • Perform charge capture audits - If your practice management system has the proper reporting functionality, it will be incredibly helpful here.  Charge-capture audits are necessary to ensure that internal procedures have been implemented and carried out properly. The information included is up to the practice, the key is to perform audits consistently.

      Coding - The Challenge

      Because of growing compliance standards, it’s becoming more and more challenging for providers to code accurately. ICD-10-CM requirements for diagnosis documentation often lead to insufficient diagnosis codes and increased workloads, both major coding risks as outlined by the Crowe report. Other frequent coding errors are using non-specific diagnosis codes or incorrect modifiers, upcoding and undercoding.

      Coding - The Solution

      • Provide ample training - Especially for inexperienced coding staff that may lack the proper knowledge to accurately code for the highest possible reimbursement. Provide up-to-date training on the most recent Centers for Medicare and Medicaid Services (CMS) guidelines. Physicians should also be included in training. Physician’s Practice suggests having a coder shadow and scribe a visit in addition to the physician’s documentation to compare what each person documents.
      • Claim scrubbing - Medical billing software solutions with built in claim scrubbing improve coding accuracy and remove manual workflows for coders.
      • Conduct regular audits - The word “audit” is typically held with a negative connotation, but auditing coders on a regular basis will bring any issues to light in a timely manner. If done with the right intentions and frequency, it’s something that doesn’t have to be painful for anyone involved. For example, instead of auditing regularly on productivity or speed, audit for quality instead. This may be an obvious tip, but it makes a big difference.
      • Subscribe to CMS updates - CMS sends quarterly updates on modified codes. It’s a good idea to subscribe to these updates so that you always have the latest medical codes. If not that, check the CMS website on a regular basis for updates.
      • Provide better documentation for physicians - Better documentation and coding-decision support for physicians can drastically improve coding accuracy, especially for highly compensated encounters that require more rigorous documentation.

      Denial Management - The Challenge

      Denied claims can be caused by numerous departments and workflows, including all risk areas we addressed above. Denied claims are three times costlier to rework than submitting a clean claim, and the challenges only compound as organizations grow.

      Denial Management - The Solution

      • Track KPIs for denial and third-party payer reimbursement - Tracking key performance indicators (KPIs) like claim submission performance, charge period revenue analysis and procedure reimbursement will identify areas for improvement in denial management and help establish a payment variance process that helps determine whether your payers are paying correctly based on the contracted rate. Receiving these reports on a daily, weekly and monthly basis will improve your ability to monitor financial reporting by leaps and bounds. Learn more about those reports in our ebook, "A Future-proofed Revenue Cycle: Prepare for 2019 with Automation."
      • Break down denials by category - Breaking the various steps of your revenue cycle down will help identify specific processes that could be causing the greatest revenue loss.  Track areas like credentialing, registration, preauthorization and charge entry.
      • Automate manual processes - According to a recent HIMSS survey, nearly a third of providers in the US are using manual denial management processes. Preauthorization, electronic remittance, auto coding and auto charge posting are areas that can be automated to help staff save time and increase accuracy in claim submission.  If your current medical billing software vendor or billing company doesn’t allow for this kind of automation, consider switching to a partner that does.

      Patient Access - The Challenge

      From financial standpoint, the lack of control over patient registration is a major risk area for providers in 2019. There are a lot of scenarios where this goes wrong, from inaccurate collection of patient information to failure to collect copayments or coinsurance in advance. Providers need a solid strategy and ample training on the front end to minimize the risk of billing issues and increase patient satisfaction.

      Patient Access - The Solution

      • Leverage tools for estimation - Adopting an estimation tool gives patients a snapshot of how much they owe out-of-pocket.  If you can inform patients about their financial responsibilities upfront, there’s a higher likelihood that they will pay their bill.
      • Perform a data clean up - While this is time intensive, performing a data clean-up can prove to be incredibly effective in wiping the slate clean and improving the accuracy of patient information.
      Intermountain Healthcare performed this process by identifying the patient, detecting the lacking demographic data, and manually editing that data to improve accuracy.  While this improved Intermountain’s patient matching rate to 60-70%, it was also done manually.  The process of updating and standardizing demographic data is laborious and expensive but certainly effective, so keep this in mind.
      • Give patients the ability to pay through an online portal - An online portal that’s integrated into your billing platform (or a medical billing company’s platform if you outsource) is beneficial for both patient and provider. Patients are given more control over their payments and have the option to pay bills in one place from anywhere. The patient’s responsibility is clearly communicated, making it easier for the patient to pay faster. It reduces follow up on co-pays, deductibles, and co-insurance balances, which translates into improved A/R.
      • Offer payment plan choices - Offering payment plans can be life changing for many patients, giving them the ability to make small payments over time without forcing themselves to choose between receiving the care they need and other necessities.  For you, it’s another step to streamlining your collection process while obtaining more patient payments.
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