U.S. Naval Hospital Naples, Italy
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PAY PATIENT BILLING PROCESS EXPLAINED

For those persons who receive an assignment to work overseas in support of a U.S. Government mission, one of the questions that arises is – “Am I eligible to use a Department of Defense (DoD) Hospital/Clinic? If so, how does the billing process work?” Below are some of the details that will help explain the process.

When stateside, persons are normally only eligible to use a military Hospital/Clinic if they are a DoD health care beneficiary (such as an Active Duty Servicemember, Retiree or Family Member), or have some other specific authorization, such as a DoD Civil Servant for occupational health care; a Reservist for Line of Duty care; a beneficiary member of the U.S. Coast Guard, NOAA or Public Health Service (pursuant to an inter-Agency agreement with that Agency); or a Veteran with a specific referral from the Veteran’s Administration (VA) (under certain Hospital-level agreements, the VA can direct a Veteran to a DoD Hospital/Clinic for care). When this sort of care is rendered, it is normally provided on a non-reimbursable (to the patient) basis.

Overseas, when under Government orders, other categories of patients receive authority to use the Military Health System (MHS) (on a reimbursable basis); the DoD Manual that explains the authority to use a DoD Hospital/Clinic, as well as the reimbursable status for those patients, is DoDM 1000.13 Vol 2 (DoD ID Cards: Benefits). And when care is authorized on a reimbursable basis, the rates (published by year) are posted on the Office of the Secretary of Defense (Comptroller) (OSD-C) website at: http://comptroller.defense.gov/Financial-Management/Reports/rates2019/ (note that neither the Hospital or Navy Medicine controls the rates that OSD-C publishes).

The method to determine whether or not a patient will have a DoDM 1000.13 eligibility is thru their registration data in the Defense Enrollment Eligibility Reporting System (DEERS). DEERS is the authoritative system that DoD uses for this purpose; it is maintained by the Defense Manposer Data Center, under the authority of the Under Secretary of Defense (Personnel and Readiness). Hospital/Clinic personnel do not establish any eligibilities; nor are they allowed/able to make any entries into DEERS; for DEERS issues, patients should contact their nearest RAPIDS (Real-Time Automated Personnel Identification System) Office.

Once arriving at a DoD Hospital/Clinic for care, registration personnel will log into DEERS and perform a real time check on the patient’s eligibility (some patients might have multiple eligibilities). Based on the data that is returned by DEERS and the reason for the visit that day, the staff will assign a Patient Category (PatCat) code to the visit; the PatCat is the code that reflects the intersection of the information returned from DEERS and compared against the DoDM 1000.13. Note, though – the PatCat does not create an eligibility – rather, it merely documents into the health record that eligibility data that already resides in DEERS. In any case, the PatCat is important, because it is the indiciator that the medical records system will use to determine whether correct or incorrect bills will eventually generate in the billing system.

After the visit is completed, the Provider will electronically complete his/her notes into the medical record and then transfer (also electronically) that record over to the Hospital’s Coding Department. Coders will review the Provider notes and assign Current Procedural Terminology (CPT) (or CPT-similar) codes to the visit. CPT codes are important, because the OSD-C rates are assigned according to each code.

It typically takes 2-3 weeks for the Provider to complete his/her notes and have the Coders review those notes/assign CPT codes. When that coding process completes, the medical billing system will use automated tools to assign the OSD-C approved rates to the codes, and then print an invoice. At that point, Hospital billing office staff will further review the bill for correctness and completeness and upload it to the Department of Treasury for processing thru their Centralized Receivables Service (CRS). When uploading the invoice to CRS, the billing office personnel will use the address on file for the patient that is listed in DEERS/CHCS; as such, it is very important that the patient maintain accurate demographic data in their DEERS profile and ensure Patient Admin department has current mailing and email address documented in your record. Without maintaining proper contact information on file, you may not receive billing information in a timely manner which has the potential negatively impact your financial record.

One day after the billing office personnel upload the invoice to CRS, Treasury will mail out a bill to the patient that lists details of the visit, along with all of the necessary Due Process notifications required by law. Also, if the patient provides an email address, then Treasury will also make an electronic notification to the patient that the invoice is ready for download from the secure Treasury bill repository at Pay.gov (if the patient does not provide an email address, then the patient can apply for a Pay.gov account after he/she receives his/her first bill in the mail). Based on OCONUS mailing timelines, receipt of the hardcopy bill can take several weeks to receive in the mail. It is highly encouraged to register an email address for electronic notifications from CRS.

CRS bills are payable within 60 days after the invoice is mailed out by Treasury; this period is established by Treasury regulation. Invoices not paid within 60 days will accrue interest (currently 1% per year); after 90 days, a 6% annual penalty rate will apply; and also after that 90 day period, the invoice will be subject to transfer to Treasury Cross Seervicing for enforced collection actions. However, if the patient cannot pay the entire balance prior to the 90 day point, he/she can request Treasury establish a payment plan. While invoices on a payment plan still accrue interest, no penalties will be applied; nor will Treasury transfer the debt for enforced collection. We strongly encourage all patients to establish an early dialogue with CRS if they are not going to be able to pay their invoice within prescribed timelines.

In order to comply with the timeframes listed in the Debt Collection Improvement Act (31 USC 3711-16) and the Federal Claims Collections Standards (31 CFR 900-904), Navy Hospitals/Clinics are not allowed to offer to file insurance claims for patients. As such, we recommend that all patients become familiar with the claims process established by their health insurer. Additionally, each CRS invoice provides a Hospital email address so that the patient can quickly contact a person who can help with any coding questions and/or requests for medical records. Note, though – while the Hospital/Clinic always has an obligation to correct any errors for instances where a bill is not supported by DEERS and/or a DoD-approved rate, the local staff cannot adjudicate disputes; for disputes, the patient should contact CRS using the instructions listed in their invoice. Also note that the Hospital cannot grant any billing waivers; all waiver requests should be referred to the offices listed in the CRS invoice.

Regarding occupational health: If you are a DoD Civil Servant or a Navy Non-Appropriated Fund (NAF) employee and either require work-related care or incur a work-related injury, you must pre-coordinate all non-emergent care thru the Hospital’s Occupational Medicine Department; and for emergent care (that is delivered in the Hospital’s Emergency Department/Urgent Care Center), you must proceed to the Occupational Medicine Department as soon as is safely possible afterwards. Without an evaluation of your care by the Occupational

Medicine Officer, you care is subject to billing according to other eligibility data found in DEERS. Also – if you are not a DoD Civil Servant or Navy NAF employee, all occupational health care is reimbursable; such, if you are a billable non-DoD Civil Servant/NAF employee, you are not bound to only using the Occupational Medicine Department.

We understand that the hospital billing process can be stressful; and while we cannot just make the bills go away, we are here to help it go as smoothly as possible. As such, if there are any questions beyond what are discussed in this article, please contact us at: usn.naples.navhospnaplesit.list.ubo@mail.mil

Billing Services / Account