This meeting convened a large group of healthcare finance, consulting, and operations professionals to discuss recent regulatory updates, operational strategies, and best practices, with a focus on the No Surprises Act (NSA), revenue cycle changes, coding updates, and remote workforce management.
Presentations included overviews of the NSA requirements, panel discussions from major Maryland health systems, detailed updates on Maryland-specific payment and compliance changes, and a session on remote workforce best practices.
Key challenges discussed were adapting to evolving compliance rules, building effective workflows for estimates and billing, and maintaining organizational culture and communication in remote and hybrid work models.
Several open questions and follow-up actions were identified, particularly regarding interpretation of regulatory requirements, patient satisfaction, compliance workflows, and remote staffing strategies.
Action Items
(ASAP – Caroline/Sarah): Integrate and monitor Menti survey and polling results for ongoing attendee feedback and CPE certification tracking.
(Within 2 weeks – Jay, Jen, and Epic/Willow teams): Finalize Epic workflow adjustments for the JW and JZ pharmacy waste modifiers; confirm Maryland-specific compliance considerations.
(Ongoing – Revenue Integrity leads at UMMS, MedStar, others): Continue to monitor, report, and refine estimate accuracy by running regular Epic/TS reports; revalidate workflows and templates as needed.
(Before July 1st – Pharmacy/Willow/Revenue Integrity teams): Identify all medication records eligible for JW/JZ modifiers and implement necessary system changes ahead of federal deadline.
(Before January 1st – Charge Master/Revenue Integrity teams): Complete all facility charge master, technology code, and RVU updates for 2023 regulatory compliance.
(Ongoing – Lauren, Kalida): Ensure CPE certificates and door prizes are distributed to attendees; address any missing certificate requests.
(Ongoing – Remote Workforce Managers): Continue development of remote team engagement strategies and feedback loops; share effective practices across organizations.
No Surprises Act (NSA) Updates & Workflow Implementation
The NSA requires all-inclusive good faith estimates (GFEs) for uninsured/self-pay patients as of January 1; government plans are exempt.
Convening providers must coordinate closely with co-providers to ensure timely, accurate estimates; strict timeframes (1-3 business days) must be followed for estimate delivery.
Epic work queues and templates are in use for both hospital-based (HB) and professional-based (PB) services; ancillary and outsourced providers present challenges for estimate accuracy and responsibility.
Centralized teams are being repurposed where possible; staff education and scripting are critical to support patient transparency without deterring care.
Dispute resolution processes triggered when charges exceed GFE by $400; proactive internal reviews recommended to avoid such cases.
Patient dissatisfaction is significant, with complaints about multiple estimate/disclosure notifications; organizations are enhancing customer service training and considering dedicated escalation/governance structures.
Ongoing struggles persist in clarifying accountability for workflow ownership and ensuring all providers (including non-affiliated and ambulatory) understand NSA applicability.
Coding, Pharmacy, and Revenue Integrity Updates
Facility charge master updates for 2023 are less extensive than prior years, except in pharmacy, where new J-codes and waste modifiers (JW/JZ) are major focus areas.
Maryland’s unique global budgeting model complicates interpretation of certain CMS requirements (e.g., JW modifier), though all are advised to proceed as if compliance is expected.
Epic and macro Helix are primary tools for managing pharmacy billing and 340B reporting; integration challenges and compliance “sniff tests” remain necessary.
New CPT and technology codes require updates to HSCRC relative value units (RVUs), with resources and support available for pricing.
Major RVU clinic rate conversions went live July 1, 2022; telemedicine and psychiatry/behavioral health remain regulatory gray areas.
Next phase of Maryland’s HSCRC task force will focus on rehab therapy and audiology RVU conversion for July 2023; all stakeholders encouraged to join discussions.
Revenue Cycle, Denials, and Operational Trends
Workforce constraints (staff shortages, repurposing, turnover) are impacting reconciliation, denials management, and overall workload.
Denials—especially in ED and ER—present challenges due to payer-specific and often opaque criteria; revenue integrity teams are increasingly involved in operations and payor negotiations.
Pandemic-driven changes, technology downtimes, and ransomware preparedness are additional operational realities.
Emphasis placed on continuous education, peer networking, and cross-organizational collaboration to interpret regulations and share best practices.
Remote Workforce Management & Culture
Remote, hybrid, and flex workforce models are now mainstream, with varying adoption based on geography, leadership philosophy, and job functions.
Best practices for remote management include frequent transparent communication, structured check-ins (AM/PM huddles), project management tools (e.g., monday.com), and creative engagement activities (e.g., virtual happy hours, team challenges).
Team building and deliberate culture-building efforts are necessary to mitigate the risks of employee disengagement and high turnover.
Recruitment strategies increasingly specify (or discuss) remote/hybrid expectations; organizations differ in job ad wording and flexibility based on institutional culture, unions, and executive direction.
Decisions
Centralization of estimate generation teams — Chosen for efficiency and bandwidth, leveraging financial counseling expertise where possible.
Use of Epic/Willow for pharmacy JW/JZ modifier compliance — Decision to proceed following Epic’s recommended workflows, subject to ongoing manual review.
Standardized language and work queue naming in Epic for NSA processes — Adopted for ease of staff training and operational consistency.
Continued education campaign for all provider types regarding NSA applicability — To ensure compliance in ambulatory and non-affiliated settings.
Hybrid/remote job postings — Most organizations deciding job flexibility at time of posting or during recruitment, balancing applicant pool size with operational needs.
Open Questions / Follow-Ups
Will Maryland hospitals be officially exempt from JW/JZ pharmacy waste modifiers under CMS rules, or should all proceed with implementation?
How to best address ongoing patient dissatisfaction over multiple estimate/disclosure notices, especially for self-pay and regulated clinics?
What additional language or disclaimers are required in GFEs when using external/portal-sourced ancillary provider rates?
How will future RVU and regulatory changes (telemedicine, psychiatry, rehab) impact workflow and patient pricing explanations?
What further support and governance are needed to support customer service and escalation related to estimate disputes and complaints?
What are best practices to measure and improve employee engagement, satisfaction, and retention in remote/hybrid work settings?