Annual Institute Keynote Speaker, North Shore LIJ CEO

Volume 46
Issue 8
Spring 2014
Annual Institute Keynote Speaker, North Shore LIJ CEO, Michael Dowling (right),
Metro NY President, David Evangelista, and Institute Chair, Maryann Reagan
www.hfmametrony.org
Page 1
2013-2014 CORPORATE SPONSORS
PLATINUM
MCRC Group
Miller & Milone, P.C.
POM Recoveries, Inc.
PricewaterhouseCoopers LLP
RTR Financial Services, Inc.
Siemens Medical Solutions
Streamline Health
TRITECH Healthcare Management, LLC
WeiserMazars LLP
BDO USA, LLP
CAB-Charles A. Barragato & CO., LLP
Craneware
Emdeon
Ernst & Young LLP
Information Builders, Inc.
Jzanus LTD.
KPMG, LLP
McGladrey LLP
GOLD
Betz-Mitchell Associates, Inc.
CBIZ KA Consulting Services, LLC
Cirius Group, Inc.
Deloitte & Touche LLP
E-Management Associates, LLC
Group J
HANYS Solutions, Inc.
HCE LLC / McBee Associates, Inc.
Health/ROI
Jzanus Consulting, Inc.
M & T Bank
MBI Associates, Inc.
Navigant Consulting, Inc.
NTT Data Healthcare Technologies
The Outsource Group
Pinnacle Strategies, Inc.
Professional Claims Bureau, Inc.
Reimbursement Services Group
SILVER
Avadyne Health
Collection Bureau of Hudson Valley - CBHV
Connex International
Convergent Revenue Cycle Management, Inc.
DGA Partners, Inc.
Garfunkel Wild, P.C.
HCCS - Health Care Compliance Strategies
Integrity Regulatory & Reimbursement
Services, LLC
Liberty Billing and Consulting Services, Inc.
M. Leco & Associates
MCS Claim Services, Inc.
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Mullooly, Jeffrey, Rooney & Flynn LLP
Nassau Suffolk Hospital Council, Inc.
NCO Healthcare Services
Passport Health Communications
Physicians' Reciprocal Insurers
The SSI Group, Inc.
TD Bank - Healthcare Lending Division
Triage Consulting Group
VALIC
Vecna Technologies
Washington & West, LLC
WithumSmith + Brown, CPA's
Page 2
Chapter Officers and Board of Directors
OFFICERS 2013-2014
President
David Evangelista
President-Elect
Wendy Leo, FHFMA
Vice President
Meredith Simonetti, FHFMA
Treasurer
David Woods
Secretary
Joseph J. Guarracino
Immediate Past President Palmira M. Cataliotti, FHFMA, CPA
BOARD OF DIRECTORS
Class of 2014
Martin Abschutz, CPA, CGMA
Donna M. Skura
Paulette DiNapoli
Robin Ziegler
James Petty, FHFMA
Class of 2015
Ann M. Amato, CPA, MBA
Diane McCarthy, CPA, CHFP
Mario DiFiglia
Maryann J. Regan
Jason Gottleib
2011-2012
2010-2011
2009-2010
2008-2009
2007-2008
2006-2007
2005-2006
2004-2005
PAST PRESIDENT
John I. Costa
Edmund P. Schmidt, III, FHFMA
Cynthia A. Strain, FHFMA
Mary Kinsella, FHFMA
Gordon Sanit, CPA, FHFMA
Elizabeth Carnevale
Jane C. Florek, CPA
John M. Scanlan, FHFMA
EX-OFFICIO
All Past Presidents of the
Metropolitan New York Chapter, HFMA
Daniel Sisto,
President, Healthcare Association of New York State
Kenneth E. Raske,
President, Greater New York Hospital Association
Kevin W. Dahill,
President & CEO, Nassau-Suffolk Hospital Council
Newscast Committee
EDITORS:
Marty Abschutz, CPA, CGMA, Editor
James G. Fouassier, JD, Esq., Assistant Editor
COMMITTEE MEMBERS:
Kiran Batheja, FHFMA
Joel Dziengielewski
Paulette DiNapoli
James G. Fouassier, Esquire
William C. Hammond, CHFP
Phil Holtzman
Mary Kinsella, FHFMA
Michael Lamothe
Wendy Leo, FHFMA
Mike McGrath, FHFMA
Andrew Natkin
Edmund P. Schmidt, III, FHFMA
Ken Sheridan
John Scanlan, FHFMA
Cynthia Strain, FHFMA
Stephanie Welsher
Metro NY HFMA Newscast Schedule
Electronic Publication Date
7/23/14
Article Deadline for Receipt by Editor
6/19/14
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President’s Message
David Evangelista ...................................................................................................................Page 5
Editor’s Message
Marty Abschutz, CPA, CGMA...................................................................................................Page 7
Calendar of Events ...............................................................................................................Page 8
New Members
Robin Ziegler ..........................................................................................................................Page 9
Committee Listings 2013-2014 ........................................................................................Page 10
The Regional Front
Bruce K. Liebel, FHFMA .......................................................................................................Page 12
Region 2 Certification Study Group Wrapping Up Its First Series
Karen Carter, CPA.................................................................................................................Page 14
HFMA Metro NY Annual Institute ....................................................................Page 15, 17, 21, 24
Metro NY HFMA 2014 Joseph A. Levi Annual Institute
What You Missed While You Weren’t There
Jason Gottleib ......................................................................................................................Page 16
PPACA Update: Final Employer Shared Responsibility Regulations Issued
Anthony J. Panico, CPA, MS..................................................................................................Page 18
What We Know, (And Don’t), About ACA Presumptive Eligibility
Marty O’Neill & Jeffrey Silvershein, FACHE...........................................................................Page 22
Tax-Exempt Status: From Charitable Care to Community Benefit
Gerald M. Swiacki.................................................................................................................Page 25
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As I sit here contemplating my final President’s Message, I can’t help smiling. No, the smile isn’t because this is my last
President’s Message and the end of my term approaches…rather it is because I am proud of the success of the Metro NY
Chapter. It seems like yesterday I was challenging everyone to “get involved” at our Annual Business Meeting back in
May of 2013. You met the challenge by continuing the tremendous attendance growth at our education programs, as well
as making their content timely and relevant.
This was certainly evident by the success of our premiere event, The Joseph A. Levi Annual Institute (AI). I was so
incredibly proud of the content of the presentations at this two day event. Under the leadership of Chair, Maryann
Regan, and Co-Chairs Christina Milone, Jason Gottlieb, Emily Casto, Jim Argutto and Robert Jacobs, the entire Annual
Institute committee worked tirelessly to provide quality educational sessions.
Many of you approached me at the AI to comment on quality of the programming, the great networking opportunities, the
vendor fair and the overall attendance. I appreciate the Metro NY Chapter members’ willingness to speak their mind
and tell me what they think…especially when it is favorable! To borrow from the movie “Field of Dreams”, If you build a
quality and timely program, they will come;we had well over five hundred attendees join us for our two day event. I
believe they turned to HFMA for answers and education at this extraordinary time in healthcare because they knew we
would deliver.
Talk about Metro NY Members speaking their minds…The results of the HFMA Membership Survey were received; 77%
of the Chapter Members responded that they were very or extremely satisfied. That is an increase of 8% from last year;
we continue to trend upward. We will carry on to strive for 100%!
I want to thank our membership for attending our educational programs and remind you that the education year is still
not over. Please visit our website http://www.hfmametrony.org to view the programs and to register.
May 14th is the date for our Annual Business Meeting to be held at the LaGuardia Marriott. Please join us in installing
our new slate of officers and board of directors. It will also be the date of our Spring Academy, which will be held during
the day at LaGuardia Marriott, prior to the Annual Business Meeting. This is a special day, as we kick off the 2014/15
education year during the day and celebrate the strong traditions of our chapter and continue networking opportunities
in the evening.
The Metro NY Chapter of HFMA will be in excellent hands with Wendy Leo as incoming President, Meredith Simonetti as
President-Elect, David Woods as Vice President, Joseph Guarracino as Treasurer and Maryann Regan as Secretary. They
are a dedicated and talented group of people who will continue the successes of the Chapter. They will be supported by
a strong Board of Directors, leadership of the Education and Social Committees, as well as a team of dedicated
volunteers. HFMA is about getting involved Please consider volunteering to serve on a Committee, this coming fiscal
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Page 5
year. I promise that you will find it to be a rewarding experience.
I would like to thank the Newscast Committee, who continually publish a quality and
interesting newsletter about and for our Chapter. A special thanks to Marty Abschutz,
Chair/Editor of Newscast and Board Member…his dedication to our Chapter is unsung. Thank
you for being a gentleman, advisor and a friend to our Chapter. Also, I’d like to recognize the
efforts of Robin Ziegler. She is the friendly face that you see at our registration desk, making
sure that the events are successful. Special thanks to our Special Events Chair, Kiran Batheja. You make HFMA fun!
Thanks for all your hard work and commitment to the Chapter. Kiran, I’ll see you at the golf outing on May 29th.
Our Chapter’s success is truly a group effort. I would like to express my sincere gratitude to all of our volunteers,
committee chairs, board of directors, officers, executive board and, especially, Palmira Cataliotti, our immediate past
president, for all of your support and dedication. Further, we are very fortunate to have so many Past Presidents who
remain involved, which makes us even stronger. Your collective efforts resulted in a successful year for the chapter, in
addition to a tremendous experience for me. I, lastly, would like to thank our Corporate Sponsors for their generous
support. Without you, our high quality educational opportunities would not be possible.
I look forward to seeing you all at an HFMA event!
David Evangelista
Chapter President 2013 -2014
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By Marty Abschutz
The Weather Outside and More...
As the spring cycling classics wind down and the Barclay’s Premier League comes up to the final games, where the League
Championship and the UEFA Champions League places (two significant passions of mine – cycling and football), the weather
is finally turning to outdoor pursuits.
While that is happening, we have several ongoing opportunities to learn about the continuing challenges and potential solutions to help our organizations succeed. We have included discussions on what you missed at the 55th Joseph A. Levi Annual Institute. Jason Gottlieb gave a terrific summary of our premier two-day event. He was gracious enough to summarize
it for these pages. Thank you, Jason!
The Patient Protection and Affordable Care Act (PPACA) is one of those continuing challenges. Chapter member, Anthony
J. Panico, CPA, MS, tells us about one of those challenges, employer shared responsibility, in the context of a February 10,
2014, Internal Revenue Service final regulation. Members Marty O’Neill and Jeffrey Silvershein, FACHE, fill us in on some
PPACA challenges related to presumptive eligibility, a thorn in every healthcare provider’s side.
Bruce Liebel, FHMA, HFMA Region 2 Executive, provides us his final thoughts on what holding that voluntary position has
meant to him. In addition, he provides plaudits to all of the chapters, including Metro NY, for their excellent Chapter Member Satisfaction Survey results. Karen Carter, CPA, acknowledges the excellent work done by the Region 2 Certification Study
Group. This was the Region’s first study group to prepare you for the HFMA national certification exams. Our own Jim Petty
and Wendy Leo, Chapter President-elect, presented and worked on the organizing committee, respectively.
On the education front, our Spring Academy is just a few weeks away. It takes place on May 14 at the LaGuardia Marriott.
On the docket is a panel discussion regarding PPACA implementation challenges. Since many aspects are covered, this
promises to be a very enlightening and lively discussion. Four breakout sessions follow the panel discussion. [Shameless
plug] Laurie Radler and I will be presenting a breakout session on Social Media for Professional Purposes. We will emphasize LinkedIn and cover Facebook and Twitter, too.
Other morning breakout sessions include Mental Health System Transformation, Clinical Integration: Concept and Realities, Chart Review: Revenue and Compliance Risks. The Chart Review session will be presented by my former Newscast colleague, Susan Montana. Sue was my predecessor Newscast Editor.
Our afternoon keynote will be Jason Helgerson, Medicaid Director, New York State Department of Health. Two-Midnight Rule,
Out of Network Provider Reimbursement, Mergers & Acquisitions and Medicaid Long Term Care Coverage are our afternoon
breakout sessions.
Past Chapter President, Bill Allison, Vice President of Fiscal Policy at the Healthcare Association of New York State, will
provide the HANYS update before moderating our CEO Panel discussion on meeting some of the PPACA challenges.
Immediately following the end of the Academy, we will hold our Annual Business Meeting and post-meeting dinner. It’s a
great social event, while dotting the “I” and crossing the “T” of Chapter business. I hope to see you there.
Lastly, special thanks to Jim Fouassier, JD, Esquire, my assistant editor. I know I can count on Jim for timely advice AND
very timely articles!
Don’t forget to keep an eye out for some of the summer programs our Education Committee is working on. Everyone have
a great summer.
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2014 IMPORTANT DATES
5/13/2014
12:00 PM FREE WEBINAR: ACA What Should You Know Now
5/14/2014
8:00 AM Spring Academy - LaGuardia Marriott
5/14/2014
6:00 PM Annual Business Meeting - LaGaurdia Marriott
6/11/2014
12:00 PM FREE WEBINAR:Demystifying Telecom Costs
FREE Webinars (Check www.hfmametrony.org for more)
HFMA Seminars provide timely, in-depth strategies and metrics to help you keep
pace with the healthcare finance topics you care about the most. View all upcoming
HFMA Seminars and register at www.hfma.org/seminars.
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The Metropolitan New York Chapter of HFMA
Proudly Welcomes the Following New Members!
By Robin Ziegler, Membership Committee Chair
MetroNY HFMA is pleased to welcome the following new members to our Chapter. We ask our current membership to roll
out the red carpet to these new members and help them see for themselves the benefits of HFMA membership. Encourage
them to attend seminars and other Chapter events. We ask these new members to consider joining a Committee to not only
help the Chapter accomplish its work, but to expand their networks of top notch personal and professional relationships.
See the list of MetroNY HFMA Committee Chairs, along with their contact information, listed in this eNewsletter.
JANUARY 2014
Sandra Perumal
SUNY College of Optometry
Jeffrey Solomon
Capital Research and Management
Amelia Shapiro
Greater NY Hospital Association
Jerald Chandy
Tim Olson
Wells Fargo Securities
Nicole Rossini
Miller & Milone
FEBRUARY 2014
Darren A De Gennaro
Union Bank
Malika Maddison
Weill Cornell Medical College
Leah Amante
Winthrop University Hospital
Nancy J Hogle
EY
Steven C. Herold
Alpha Systems
Chris Jurik
Hospital for Special Surgery
Christopher L Stein
Bostwick Laboratories
Nick S Delmonico
JP Morgan Chase
Nancy Ortiz
Medical Receivables Billing Group
Christina L Cool
Presscott Associates-ParenteBeard
Luis de la Prida
Island Urgent Medical Care, P.C.
Christine A Stehlik
Good Samaritan Hospital Medical Center
Felicia Jackson
KPMG
Shawn Huda
PricewaterhouseCoopers
Kimberly A Ream
Quorom Health Resources, Inc.
Jim Cross
Blue Sky Capital Stategies
Lily R. Gilbert
KPMG
Arlene Sepulveda
Montefiore Medical Center
Benjamin Iskhakov
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Committee Name
Chair
Co-Chair
Vice Chair 1
Vice Chair 2
Advisory Council
Palmira Cataliotti
[email protected]
(516) 663-2311
John Coster
[email protected]
(516) 240-8147
Ed Schmidt
[email protected]
(516) 572-4834
Cindy Strain
[email protected]
(516) 796-3700
55th Annual
Institute
Maryann Regan
[email protected]
(516-576-5601
Jason Gottlieb
[email protected]
(212) 297-4549
Christina Milone
[email protected]
(516) 509-0277
Bob Jacobs
[email protected]
(516) 616-0200 ext. 201
Emily Casto
[email protected]
(614) 263-1043
Jim Argutto
[email protected]
(631) 761-1028
Auditing
[email protected]
Gordon Sanit
[email protected]
(516) 918-7065
Fred Miller
[email protected]
(516) 393-2250
Diane Masi
[email protected]
(516) 551-5839
John Scanlan
Al Farina
[email protected]
(914) 365-3508
David Evangelista
[email protected]
(718) 206-6930
Cathy Ekbom
[email protected]
(516) 745-0161
John Scanlan
Certification
Coaching
(718) 283-3911
Joe Guarracino
[email protected]
(718) 250-6755
Robin Ziegler
[email protected]
(516) 338-1100 x314
Jim Petty
[email protected]
(516) 876-6022
Certified Members
Kiran Batheja
[email protected]
Community
Outreach
Josephine Vaglio
[email protected]
(516) 248-2422
Steven Stella
[email protected]
(516) 326-0808
Ann Amato
[email protected]
(516) 632-3405
John Scanlan
Bylaws
Central
Registration
Continuing Care
Corp. Compliance/
Internal Audit
CPE’s
DCMS/Balanced
Scorecard
Exec. Comm.
& Planning
Finance/
Reimbursement/Audit
Founders Awards
General
Education
HIM/UR
www.hfmametrony.org
[email protected]
(718) 283-3911
Kiran Batheja
[email protected]
Joe Guarracino
[email protected]
(718) 250-6755
Palmira Cataliotti
[email protected]
(516) 663-2311
Annie Lemoine
[email protected]
(516) 326-0808 x3312
Art Cusack
[email protected]
(516) 546-4198
Michael McGrath
[email protected]
(516) 656-5374
David Evangelista
[email protected]
(718) 206-6930
Lauri Radler
[email protected]
(516) 616-0200 ext 216
[email protected]
(718) 283-3911
Diane Masi
[email protected]
(516) 551-5839
David Evangelista
[email protected]
(718) 206-6930
Mario DiFiglia
[email protected]
(516) 876-1386
Paulette DiNapoli
[email protected]
(516) 576-5638
Donna Skura
[email protected]
(516) 572-4498
Annie Lemoine
[email protected]
(516) 326-0808 x3312
Robin Ziegler
[email protected]
(516) 338-1100 x314
Wendy Leo
[email protected]
(516) 454-0700
Kwok Chang
[email protected]
(212) 979-4324
David Evangelista
[email protected]
(718) 206-6930
Wendy Leo
[email protected]
(516) 454-0700
Rachele Hashinsky
[email protected]
(646) 227-3156
Sean Smith
[email protected]
(516)
Cathy Ekbom
[email protected]
(516) 745-0161
Co-Chair: Diane Masi
Diane McCarthy
[email protected]
[email protected]
(516) 551-5839
(631)391-7748/
Stacey Levitt
[email protected]
(646) 732-5052
Co-Chair:Jason Gottlieb
[email protected]
(212) 297-4549
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Committee Name
Historian
Legal Affairs
Link Committee
Managed Care
MSP
Membership
Marketing
Medical
Grp Mgmt.
MIS
Newscast
Nominating
Patient Financial
Services
PPDD
Webmaster and
Personnel
Placement
Public Relations &
Communications
Region 2
Region 2
Collaboraton
Committee
Ryan Award
Social Events
Sponsorship
Yerger Award
Chair
Co-Chair
Michael McGrath
[email protected]
(516) 656-5374
Fred Miller
[email protected]
(516) 393-2250
Rich Nagy
[email protected]
(631)444-4175
Rich Nagy
[email protected]
(631)444-4175
Paul Cheng, Jr.
[email protected]
(347) 581-7573
Christina Milone
[email protected]
(516) 509-0277
Jason Gottlieb
[email protected]
212 297-4549
James Fouassier
[email protected]
Vice Chair 1
Vice Chair 2
Peter Egan
Patrick Nolan
[email protected]
(212) 430-6620
(631) 638-4012
Michael McGrath
Kiran Batheja
[email protected]
[email protected]
(516) 656-5374
Robin Ziegler
Diane Masi
[email protected] [email protected]
(516) 338-1100 x314
(516) 551-5839
Josephine Vaglio
Diane McCarthy
Heather Miskovic
[email protected]
[email protected]
[email protected]
(516) 766-0521
(631) 391-7748
(631) 454-4081
John Mertz
Annie Lemoine
Ann Amato
[email protected]
[email protected]
[email protected]
516-632-3170
(516) 326-0808 x3312
(516) 632-3408
Marty Abschutz
James Fouassier
[email protected]
[email protected]
(732) 906-8700 ext 109
(631) 638-4012
Palmira Cataliotti
[email protected]
(516) 663-2311
Paulette DiNapoli
Cathy Ekbom
Patrick Nolan
[email protected]
[email protected] [email protected]
(516) 576-5638
(516) 745-0161
(212) 430-6620
Palmira Cataliotti
Cindy Strain
[email protected]
[email protected]
(516) 663-2311
(516) 796-3700
Mary Long Kinsella
Cindy Strain
[email protected]
[email protected]
(212) 297-5445
(516) 796-3700
Emily Casto
Michael Lamothe
[email protected]
[email protected]
Phil Holtzman
(614) 263-1043
(646) 227-2396
Cindy Strain
John Coster
Kiran Batheja
[email protected]
[email protected]
[email protected]
(516) 796-3700
(516) 240-8147
Diane McCarthy
Diane Masi
Meredith Simonetti
[email protected]
[email protected]
[email protected]
(631) 465-6877
(516) 630-3911
(516) 551-5839
Palmira Cataliotti
[email protected]
(516) 663-2311
John Coster
John Mertz
Kiran Batheja
[email protected]
[email protected]
[email protected]
(516) 240-8147
(516) 632-3170
Michael McGrath
David Evangelista
David Woods
[email protected]
[email protected]
[email protected]
(516) 656-5374
(718) 206-6930
(212)979-4566
Dana Keefer
Art Cusack
[email protected]
(212) 226-8866
Gordon Sanit
[email protected]
(516) 918-7065
[email protected]
(315) 938-5624
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Page 11
By Bruce K. Liebel, FHFMA, Regional Executive 2013-14
Welcome to the Spring Edition of my final “The Regional Front”, where as Regional Executive, I’ve been
providing information on our seven chapters. It’s been a pleasure communicating chapter, regional, and
national HFMA information to you.
This month’s article has a little different twist, as I’m starting by going back to the President’s Message I wrote for the
Spring 2008 edition of ‘Fine Print’ – the Western New York newsletter, and getting my inspiration.
My President’s Message back then started with the word PRIDE. I wrote how that word did not have a lot of special meaning
to me until my son Tom joined the U.S. Army. His transformation after 8 weeks of boot camp at Ft. Jackson in South
Carolina, led to training time at Ft. Lee, Virginia, then assignment to Fort Carson in Colorado Springs. It was at that time
of my message that my family and I were preparing for his deployment to Iraq. Though it was going to be tough on us, we
were proud of his commitment to his job, in serving our country.
Sgt. Thomas W. Liebel, Carmela Liebel & Bruce
From there I went on to convey my thoughts in serving as President of the WNY Chapter of HMFA. With the help of a
committed team of volunteers, we were able to accomplish a lot – meeting goals, improving the chapter, and “Making a
Difference” in our jobs, organizations, and even our communities. The chapter also provided me with much, with their
confidence, trust, friendships, and the push to join the ranks of certified members. Yes, another type of PRIDE in and what
our team was able to accomplish and provide our members., along with the opportunities afforded me.
Fast forward to April 2014, where much has changed, but really, much has not. My son notified us last month that he is to
be deployed next month to Kuwait for 9 months. After a 3-year stint in Germany, a promotion to Sergeant, and a recent
move to Ft. Huachuca in Arizona, he continues to serve our country well. We have been fortunate to have visited him at
each stop, but while it tests our strength being away for long periods, what does not change is the PRIDE we have for him
and his family, with their service.
And me, with but one month left in my term as Region 2 Regional Executive, I would have thought that I could not have been
more proud of HFMA after having served as chapter President, but I have more PRIDE in it after having served in this
position. Following the footsteps of Tom Crilly and a great line of Region 2 RE’s, last May I oversaw a rewarding Mini-LTC
in Cooperstown, followed by the accomplishments of our Fall President’s Meeting in August. Shortly thereafter in October,
I had the satisfaction of witnessing a great Region 2 Institute, which was the result of working with a great team of
coordinators for almost ten months, along with a group of chapter volunteers that came together in the end to assist us.
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Page 12
By Bruce K. Liebel, FHFMA, Regional Executive 2013-14
Being in constant contact throughout the year with the 2013-14 Chapter Presidents, via meetings, conference calls and
emails, I was able to hear of their accomplishments and concerns. It showed me not only their commitment to this
organization, but to their members as well. It has led me to believe more in HFMA and its volunteer leaders, and to that I
must say ‘THANK YOU’ to Karen, Kristen, Chris, David, Jeffrey, Julio & Rabin.
As for the President-Elects, I see them ready to move up and successfully lead their chapters. With the help of the incoming
Regional Executive, Teresa Figueroa, from Puerto Rico, the Region is in good hands. I can’t thank Teresa enough for her
support this past year, along with her friendship. Waiting in the wings as RE, is Mollie Kennedy, from Northeastern New
York, who I know will do a great job as well.
The culmination of the year will be the upcoming opportunity to witness our Chapter Presidents walk on stage at ANI in June
to receive, not only their chapter awards, but the expected Region 2 Yerger Awards, that are a result of the collaboration
of the seven chapters.
As I reported at several sessions this year, our chapters should be most proud of the results of the annual Chapter Member
Satisfaction Survey. Below they show that for the last 5 surveys, REGION 2 is #1 in the NATION, as a result of the 7
chapters combined efforts.
Members' Overall High Satisfaction Ratings: FY06 to FY10: Worst to FIRST!
Region
1
2
3
4
5
6
7
8
9
10
11
FY14
73.0
78.4
68.8
70.0
69.2
70.0
63.4
73.2
66.3
63.5
59.3
FY13
65.8
71.7
64.1
69.1
63.4
65.1
60.8
69.6
67.9
67.0
61.8
FY12
60.3
71.8
55.8
61.1
57.1
62.9
61.6
66.1
62.7
62.0
57.7
FY11
61.9
68.8
65.9
62.7
58.7
63.1
62.5
67.6
59.7
57.5
54.4
FY10
51.6
62.1
62.0
54.0
48.6
56.6
55.0
57.8
57.1
51.6
47.1
FY08
52.0
56.5
58.1
57.0
53.0
54.5
56.1
58.5
58.1
49.5
52.6
FY06
48.6
44.7
48.7
52.2
50.8
45.3
53.1
51.9
54.1
49.6
49.2
Yes, PRIDE; a word that continues to take on more meaning, as I soon leave the helm of this group. I cannot be any prouder
of what we have been able to provide our members and accomplish as a Region, and cannot thank you all enough for the
opportunities it has afforded me. Allowing me to be your representative at the Regional Council Meetings and in
communications with National HFMA, and entrusting me to lead your meetings and Institute, I only hope that I have fulfilled
the role as well as those that have gone before me.
In friendship and with my special thanks, Bruce
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Region 2 Certification Study Group Wrapping Up Its
First Series
By: Karen Carter, CPA
I just wanted to take a quick second to update you on the Region 2 Certification Study Group. Michele Mecomonaco has
told me that the group will be wrapping up its first series on April 25th. There was a kick off call followed by 8 webinars,
and now the group is in a Q&A period.
I am very excited about the group and the potential positive impact for our members and our certification goals.
The volunteers that have been involved in the establishment of this webinar series have put in quite of a bit of work, so I
am hopeful that as Presidents you will be sure to thank them for their efforts (and for those of you who ARE the
volunteers...THANK YOU!). Founders’ points would be appropriate for each committee member’s participation, and speaker
points would be appropriate for the presenters.
The volunteers involved are:
Committee:
Central
Metro NY
Rochester
Hudson Valley
NENY
Michele Mecomonaco
Wendy Leo
Diane Lage
Marianne Muise
Tige Monacelli, Rabin Kayastha
Presenters:
Rochester
NENY
Rochester
Hudson Valley
Hudson Valley
Hudson Valley
Hudson Valley
Hudson Valley
Central NY
Metro
Central NY
Diane Lage
Paul Segovis
Rachelle Fletcher
Kelly McGinnis
Bob Shaw
Will Scheuermann
Barbara Voight
Barbara Piascik
James Godleski
Jim Petty
Michele Mecomonaco
Karen A. Carter, CPA - Vice President of Finance/Chief Financial Officer
Laboratory Alliance of Central New York, LLC
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Metro NY HFMA 2014
Joseph A. Levi Annual Institute
What you missed while you weren’t there
By: Jason Gottlieb
Editor’s Note: The following is a summary from the remarks
that Jason Gottlieb delivered at the end of the Annual
Institute on Friday, March 14, 2014, as one of the Co-Chairs
of the event.
Sitting from atop his perch at one of the largest not-for-profit
integrated delivery systems in the nation, North Shore-LIJ
Health System President and Chief Executive Officer, Michael
Dowling, implored the 530 attendees at the 2014 Joseph A.
Levi Annual Institute (AI) to “lead from the front.” “We’re right
and they’re wrong,” Mr. Dowling deadpanned, as he referred
to the government’s involvement in shaping and defining the
way healthcare will be delivered in the future.
Such messages set the tone for the signature two day event
of the Metropolitan New York Chapter of the Healthcare
Financial Management Association. The AI was held on
March 13 - March 14 at the LaGuardia Marriott in Queens,
New York. During a record turnout, participants networked,
engaged, and learned how their industry peers, local
competitors, and personal colleagues are all doing “whatever
it takes,” (HFMA National Chair Steven Rose’s signature
theme) to lead the transition to a value based healthcare
system.
Presentations and panel discussions covered topics ranging
from innovations in managed care and insurance coverage,
physician alignment, to the continuing evolution in the
relationship between clinical and financial leadership,
population health, and the political landscape. Several
common themes synergized the event.
The industry is getting smaller. One only needs to look to
our own backyard to recognize that hospitals and physician
practices are consolidating to create leverage for an
uncertain future. But consolidation doesn’t just mean fewer
participants. Smaller reimbursements driven by the
transition from large inpatient to smaller outpatient services
provided in smaller structures of specialized care will
continue to challenge the traditional healthcare delivery
mechanisms. The hospital may no longer be the icon of
healthcare delivery.
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Data is getting bigger and is paramount to transformation.
While claims data has been the de facto source for analyzing
the delivery and quality of healthcare, the maturing and
evolving electronic health record (EHR) and the innumerable
digital healthcare delivery and monitoring technologies will
need to create a digital wisdom that empowers real time
clinical, operational, and financial decision making.
Risk is inevitable, learn to manage it. The human body is the
most complex system in the world. Delivery of care to that
system is no less complex. There will always be unknowns.
Diligence and contingency are the constants that can control
variability. The continued simplification and alignment of
the clinical and financial conversation is imperative.
The patient has to be part of the transformation equation.
But how do we do a better job of this? Lack of patient
engagement will place a ceiling on the amount of change the
industry can affect. Yes, monetary incentives have their
place, but, ultimately, do not engage the patient for the right
reasons; that being to invest and take accountability for one’s
health. Healthcare providers’ biggest challenges may be in
defining the transformative approaches, tools, and solutions
that dare a patient to live healthier.
Value is not better quality at lower cost but better quality at
the right cost. There are reasons we pay $6.00 for coffee
when we know we can pay $2.00. Yes, the cost of healthcare,
by most definitions, is too high in this country. Much of that
is based on the perception of what we get for our dollar.
Deliver a superior patient experience with a superior patient
outcome and cost can be justified.
On behalf of the Metropolitan New York Chapter of HFMA,
we’d like to thank all the speakers, panelists, moderators,
special guests, and chapter members who contributed to
delivering this outstanding event. We’d also like to extend
our sincere appreciation to the more than 500 people who
registered and attended and are hopeful they received a
“value-based experience.” We look forward to seeing you
next year at the 2015 Joseph A. Levi Annual Institute.
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PPACA Update: Final Employer Shared
Responsibility Regulations Issued
By: Anthony J. Panico, CPA, MS
The U.S. Treasury Department (“Department”), on February 10th, issued final regulations implementing the employer
shared responsibility provisions of the Affordable Care Act (“ACA”). The final regulations provide transitional relief for large
and mid-sized employers, including hospitals and physician practices, and address several other areas related to the
employer shared responsibility provision of the ACA.
Background
Under the ACA and Internal Revenue Code (“IRC”) §4980H, an applicable large employer that, for a calendar month, fails
to offer to at least 95% of its full-time employees health coverage that is both affordable and provides minimum value may
be subject to a penalty if any of its full-time employees for that month purchase a qualified health plan through a state-based
marketplace through the use of a premium tax credit or subsidy. An applicable large employer is defined as one that
employed, during the preceding calendar year, an average of at least 50 full-time employees, including full-time equivalents.
Coverage under an employer-sponsored plan is deemed to be affordable for an employee as long as the employee’s required
contribution toward the cost of single only health coverage does not exceed 9.5% of their household income. In order for
employers to be able to determine household income, several safe harbors exist. For example, an applicable large employer
is able to use an employee’s Form W-2, Box 1 wages as household income. Other safe harbors include hourly rates paid to
employees or Federal poverty level. Coverage under an employer-sponsored plan provides minimum value as long as the
plan’s share of the total allowed costs of benefits provided under the plan is at least 60% of those costs. A health plan meets
this standard if it is designed to pay at least 60% of the total cost of medical services for a standard population.
The employer shared responsibility provision as originally drafted was set to be effective on January 1, 2014. Last summer,
the IRS issued Notice 2013-45 delaying the effective date of this provision to January 1, 2015. The release of these final
regulations provides further transitional relief for certain employers.
Definition of Full-Time Employee
For purposes of the employer shared responsibility provision, a full-time employee is defined in the final regulations as an
employee, with respect to a calendar month, who is employed and provides an average of at least 30 hours of service per
week, or 130 hours of service per month.
Transitional Relief
As noted earlier, the final regulations provide transitional relief for large and mid-sized employers. The Department has
stated that this transitional relief was instituted to ensure a gradual phase-in of the employer shared responsibility provision
and to assist employers that are subject to the provision.
Applicable large employers that have at least 50 but no more than 99 full-time employees, including full-time equivalents,
have been granted an additional year until January 1, 2016 to comply with the employer shared responsibility provision.
In addition, applicable large employers that have 100 or more full-time employees, including full-time equivalents, are still
subject to the employer shared responsibility provision on January 1, 2015; however, they will only be required to offer
health coverage that is affordable and provides minimum value to at least 70% of their full-time employees during 2015.
This will increase to the 95% indicated above effective for the 2016 calendar year. The Department believes that this
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transitional relief will assist employers that, for example, may be currently offering coverage only to those employees that
work an average of 35 hours per week or more but not yet to those employees that work an average of between 30 and 34
hours of service per week.
To qualify for the transitional relief, employers must provide appropriate certification as defined in the final regulations.
Types of Employees
The final regulations also address and provide clarification with respect to certain types of employees or occupations and
whether or not these employees are considered full-time for purposes of the employer shared responsibility provision. The
Department provides the following in a Fact Sheet which summarizes the final regulations:
Bona fide volunteers of government or tax-exempt entities, such as volunteer firefighters, will not be considered full-time
employees.
Teachers and other educational employees are to be treated as full-time even if their school is closed or operating on a
limited schedule (e.g. summer).
Seasonal employees with customary annual employment of six months or less generally will not be considered full-time
employees.
Service performed by students under federal or state-sponsored work-study programs will not be counted in determining
whether or not they are full-time employees.
Until further guidance is issued, employers of adjunct faculty are to use a method of crediting hours of service for those
employees that is reasonable in the circumstances and consistent with the employer shared responsibility provision. The
final regulations expressly allow crediting an adjunct faculty member with 2¼ hours of service per week for each hour of
teaching or classroom time as a reasonable method for this purpose.
Other Provisions
Certain other provisions that were originally slated to take effect in 2014 that have already been delayed until 2015 still
remain:
To help accommodate employers that will be subject to the employer shared responsibility provision for the first time,
employers can determine whether they had at least 100 full-time employees, including full-time equivalents, in the
previous year by reference to a period of at least six consecutive months; instead of a full year.
Employers with non-calendar year plans will not be subject to the employer shared responsibility provision until their
plan year starts in 2015; not on January 1, 2015.
The policy that employers offer coverage to their full-time employees’ dependents will not apply in 2015 to employers
that are taking steps to arrange for such coverage to begin in 2016.
On a one-time basis, in 2014 preparing for 2015, plans may use a measurement period of six months even with
respect to a stability period - the time during which an employee with variable hours must be offered coverage - of
up to 12 months.
The Department has stated that as these limited transition rules take effect, they will take into consideration whether or
not it will be necessary to further extend any of them beyond 2015.
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Conclusion
Although the enforcement of the employer shared responsibility provision for certain employers has been delayed, it is
important for employers to consider the potential applicability of this provision in the future. It is estimated that 96% of
employers are small businesses and have less than 50 employees thus exempting them from the employer shared
responsibility provision. The Department has indicated that final regulations with respect to the employer reporting
requirements associated with the employer shared responsibility provision under IRC §6055 and §6056 will be forthcoming
from the Internal Revenue Service (“IRS”). In addition, the IRS has released a series of 46 questions and answers related
to employer shared responsibility which can be accessed via the newsroom section of the IRS’ website (www.irs.gov):
“Questions and Answers on- Employer Shared Responsibility Provisions Under the Affordable Care Act.”
About the Author
Anthony J. Panico, CPA, MS, is a partner with WithumSmith+Brown, Certified Public Accountants and Consultants. He is
an active member of the firm’s Healthcare Services Group and Team Leader of the Healthcare Reform Advisory Team.
Based in the Morristown, NJ office, Tony can be reached at [email protected].
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What We Know, (And Don’t), About ACA
Presumptive Eligibility
By: Marty O’Neill, President, HCE, LLC
Jeffrey Silvershein, FACHE, Principal, McBee Associates, Inc.
An important part of the ACA for healthcare providers is the provision that expands Medicaid Presumptive
Eligibility (PE). The goal of the expanded PE is to encourage the public to participate in the ACA at this limited
level as a step toward full enrollment in the ACA.
This coverage is provided so that a patient can receive Medicaid coverage while receiving healthcare, before a
full application has been officially processed. Presumptive eligibility is a federally authorized program that states
can opt into. New York State has indicated that they will be opting to offer the ACA expanded PE.
Today, in New York State, PE is available for pregnant women through PCAP, (Peri-natal Childcare Assistance
Program) and children through CHIP, (Children’s Health Insurance Program). Presumptive eligibility benefit
coverage commences on the date the patient receives care which would be indicated on the application. Under
the ACA, a broader group of beneficiaries will be considered for eligibility. Regulations published indicate that
anyone who applies for PE can be eligible, provided they meet specific criteria. The specific requirements have
not been released by New York State Department of Health. However, with all the turmoil around enrollments,
exchange plans, etc. this important piece of ACA has not been a hot topic of discussion, yet. The expansion of
PE will be a very important issue for healthcare providers to consider.
The expanded PE will include adults and parents and this can impact revenue and cash flow and possibly reduce
your Charity Care accounts. The following information is based on research and conversations with state officials.
From this information, you will get a baseline understanding of the federal and state level requirements and the
implications and responsibilities for the healthcare providers that opt to offer its consumers PE. Many details
are not yet finalized as you will see later.
At the federal level, the following are the key points to consider:
• States have to establish oversight procedures to monitor PE programs to insure compliance with federal
requirements and their own Medicaid guidelines.
• Standards will have to be established to avoid the overuse and abuse of PE by the hospitals.
• States will receive full federal matching funds if a full Medicaid application is ultimately filed and a
determination is made.
• States have to use their existing Medicaid eligibility income levels for PE determinations.
• States have to establish levels of usage for individuals, i.e: the number of times that a consumer can
apply for PE within a specific period.
• States cannot hold a hospital liable if a person is enrolled presumptively, but later denied on a full
Medicaid application. [However, hospitals need to be smart about the PE enrollment process for
patients. If a hospital enrolls an eligible through the PE process whom they know will be denied Medicaid
eligibility later, there can be serious consequences.]
State level considerations include:
• NYS also has to establish usage levels, such as the number of times an individual can request PE in a
specific time period.
• There will need to be a mechanism that prevents an individual from going from hospital to hospital
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requesting PE. This issue hasn’t yet been specifically addressed.
• Hospitals that offer PE, must also offer the full Medicaid application to the consumer.
• Hospitals will have to adhere to reporting state guidelines to show the rate of PE applications that
develop into a full Medicaid application.
To Be Determined
We had a discussion with an official from NYS DOH and currently the state has not formulated all the necessary
procedures for implementing the expanded PE. Here are some of the open issues:
• As of the time of this printing, the PE application has to be fully developed by the state.
• A decision has yet to be made on whether the application will be submitted electronically and/or via
paper filing.
• NYS has to determine if there will be a residency and legal residency requirement for PE. However,
verification of either cannot be a condition of eligibility.
• Training manuals and schedules have yet to be created.
• The length of the eligibility period for PE has yet to be established.
• A decision is needed on how PE decisions are communicated to the consumer and the provider.
• Based on the issuance of PE, should the patient be found to be ineligible for Medicaid, it is unclear
whether the hospital will be obligated to complete an insurance application through the exchange.
• Performance benchmarks will be required for evaluating effectiveness of the program.
• A metric still has to be developed to measure the provider’s performance in submitting applications
without errors or omissions.
There are still some remaining issues in the presumptive eligibility program/process that are not addressed and
they will need to be decided to account for different patient/application situations.
For the hospitals and providers, there is time to assess whether to offer PE applications and how the process can
be structured within your current work flows. However, like many new programs, as it is rolled out, the original
idea will be modified as the realities of the real healthcare world meet the theory.
One big benefit of PE is that ACA will issue the state full matching federal funds for all covered services, even if
the applicant is later denied Medicaid eligibility. More importantly, the state cannot hold the hospital liable, if
the PE applicant is denied by Medicaid. This may be a significant revenue opportunity that otherwise might not
be available.
The downside is that if the Medicaid application cannot be completed and submitted, it seems, although not
specifically stated, that the hospital may be responsible to return any PE reimbursements.
For now, with all the changes that are going on with ACA and the state takeover of Medicaid eligibility, we have
to be prepared to move once NYS DOH issues their final instructions.
Marty O’Neill
President
HCE, LLC
www.hfmametrony.org
Jeffrey Silvershein, FACHE
Principal
McBee Associates, Inc.
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Tax-Exempt Status: From Charitable Care
to Community Benefit
By: Gerald M. Swiacki is a senior vice president with Lancaster Pollard
Nonprofit hospitals are in a new era of compliance, with reporting obligations now inextricably tied to an organization’s taxexempt status. Two recent notices from the IRS attempt to provide more clarity for hospital leadership.
Internal Revenue Code (IRC) Sec. 501(r), which sets forth requirements nonprofit hospitals must meet in order to maintain
federal tax exemption under IRC Sec. 501(c)(3), was created with passage of the Affordable Care Act (ACA) in 2010. More
than half of all hospitals in the United States are nonprofit. Thus, IRC 501(r) will have a significant impact on the manner
in which health care will be provided in the local community and across the country.
Charitable Care, Community Benefit
In 1956, the IRS standard for tax exemption required hospitals to provide charity care to the extent of their financial ability.
“Community benefit” was first articulated by the IRS in 1969. While charity care remained an important component,
hospitals were required to expand efforts and promote health to a class of persons broad enough to benefit the community.
The standard remained essentially unchanged until 2009 when the IRS introduced a new Schedule H to supplement financial
data collected from all tax-exempt organizations. Enactment of the ACA presented another opportunity to expand and clarify
federal community benefit requirements, establishing criteria related to the assessment of community health needs; financial
assistance policies; and hospital charges, billing and collection practices.
501(r) provides that a hospital organization will not be afforded tax-exempt treatment under 501(c)(3) unless the hospital
meets requirements of 501(r)(3) through (r)(6):
501(r)(3) requires a hospital organization to conduct a community health needs assessment (CHNA) every three
years and implement a strategy to meet those needs.
501(r)(4) requires a hospital organization to establish a financial assistance policy (FAP) and a policy related to
emergency medical care.
501(r)(5) limits amounts charged for emergency or other medically necessary care that is provided to individuals
under the hospital’s FAP to not more than the amounts generally billed to insured individuals.
501(r)(6) requires reasonable efforts to be made to determine whether an individual is FAP-eligible before engaging
in extraordinary collection actions.
There is considerable guidance from tax and legal professionals regarding the nuances and best practices for complying with
the requirements of 501(r), including the dynamic nature of the CHNA process and the need for its conclusions and
responses to be thoroughly documented.
Notices, Proposed Regulations and Procedures
Implementation of 501(r) has not been without challenges and the IRS has attempted to resolve a wide variety of issues
through notices and publication of proposed and temporary regulations. It is in the absence of statutory guidance that
proposed regulations offer organizations the best instruction on compliance. Most recently (i.e., on Dec. 30, 2013), two more
notices provided guidelines for affected organizations. Notice 2014-2 confirmed that tax-exempt hospital organizations
may rely on proposed regulations under 501(r) before final regulations are published. Notice 2014-3 provided correction
and disclosure procedures for certain failures to meet the requirements under 501(r).
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With the issuance of Notice 2014-2, nonprofit hospitals are provided a clear methodology for compliance with 501(r) based
on the proposed regulations dated June 26, 2012 and April 5, 2013. For the earlier guidance, information was provided on
the requirements for charitable hospitals relating to financial assistance and emergency medical care policies, charges for
emergency or medically necessary care provided to individuals eligible for financial assistance, and billing and collections.
CHNA requirements were covered in April 2013 along with a discussion on the related excise tax and reporting requirements
for charitable hospitals as well as consequences for failure to satisfy 501(r). The 2013 proposed regulations also specified
that failure would be excused (i.e., no loss of tax-exempt status), if a hospital corrected and disclosed errors and omissions
promptly after discovery.
Most tax-exempt hospitals were required to meet the CHNA requirement set forth in 501(r)(3) by the end of 2013. As for
those organizations that made a good faith effort to comply by the deadline, issuance of Notice 2014-2 on Dec. 30 might
be considered anything but timely. Fortunately, Notice 2014-3 includes a proposed revenue procedure allowing nonprofit
hospitals to maintain favorable tax treatment when failure is neither willful nor egregious.
A Road Map for Hospitals
The proposed correction and disclosure procedures of Notice 2014-3 provide a road map for organizations seeking to
excuse one or more failures as long as action begins before the hospital is contacted by the IRS concerning an
examination. Correction includes the following four principles:
Attempt to restore affected persons to the position they would have occupied had the failure not occurred.
Take action reasonable and appropriate to the failure.
Make the correction as quickly as possible after discovery.
Establish or modify policies and procedures to prevent similar failures from recurring.
Disclosure on Schedule H of Form 990 for the tax year in which the failure is discovered requires:
A description of the failure, including its type, location, date, number of occurrences, number of persons affected
and dollars involved, along with the cause of the failure and practice and procedures in place prior to the occurrence.
A description of the discovery, including how it was made and timing.
A description of the correction made, including the method and date of corrections and whether affected persons
were restored.
A description of the practices and procedures, if any, that were established or modified or an explanation as to why
no changes were needed.
The IRS states that correction and disclosure does not create a presumption that failure was not willful or egregious.
However, correction and disclosure in accordance with the proposed revenue procedure will be considered as a factor and
may serve as an indication that failure was not egregious or willful.
It is important to note that minor and inadvertent omissions and errors due to reasonable cause will not be considered a
failure to meet a requirement of 501(r), if corrective action is taken promptly after discovery. By contrast, a failure to meet
the CHNA requirements of 501(r)(3) subsequently excused as a result of appropriate correction and disclosure actions may
still result in the imposition of an excise tax.
501(r): A Shift in Emphasis
The IRS continues to focus on activities and policies of nonprofit hospitals while capturing information to ensure compliance
with the ACA. However, many of the provisions of 501(r) were effective for tax years beginning after the date of enactment.
As such, and without final rules and regulations, the challenge for affected organizations has been to avoid failure. A recent
notice confirms certain proposed regulations can be relied upon for compliance pending the publication of final regulations
or other applicable guidance. Another new notice proposes procedures to correct and disclose failures to comply with the
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requirements of 501(r).
Policy analysts predict less demand by uninsured patients for free and discounted hospital care as the ACA is implemented.
The anticipated result is greater resources at nonprofit hospitals to focus on community benefits. The entire industry is
shifting from managing illness to promoting wellness. Nonprofit hospitals, in return for retaining favorable tax treatment,
are expected to contribute by creating and expanding public and community health initiatives throughout the communities
they serve. 501(r) appears to be the tool by which the shift from an emphasis on charitable care to community benefit will
be accomplished.
Gerald M. Swiacki is a senior vice president with Lancaster Pollard. He manages the Southeast region and is
based in the firm’s Atlanta office. He may be reached a [email protected].
Hyperlinks:
501(c)(3)
http://www.irs.gov/Charities-%26-Non-Profits/Charitable-Organizations/New-Requirements-for-501(c)(3)Hospitals-Under-the-Affordable-Care-Act
Notice 2014-2
http://www.irs.gov/pub/irs-drop/n-14-02.pdf
Notice 2014-3
http://www.irs.gov/pub/irs-drop/n-14-03.pdf
Schedule H
http://www.irs.gov/pub/irs-pdf/f990sh.pdf
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