Dealing with Health Insurance Fraud, Abuse & Waste GHANA’S PERSPECTIVE Reforms in Ghana’s Health 1957 Free health care policy implemented. 1970s Ghana experienced economic shocks and began structural adjustment programmes. Nominal payments for health services introduced. 1985 User fees (cash & carry) was introduced. This policy excluded majority of people from access to healthcare 1990s Community-based mutual health insurance schemes were introduced. 2000 High out-of-pocket expenditure on health and very low utilization of health services. 2003 National Health Insurance introduced. BACKGROUND Your access to healthcare • • • The NHIS was established by an Act of Parliament in 2003 (Act 650). Initiative by Government to secure financial risk protection against the cost of healthcare services for all residents in Ghana. Act was revised in 2012 – NHIS Act 850 Funding - Combination of the following models Bervridgian: National Health Insurance levy - 2.5% VAT Bismarkian: 2.5 percentage points of Social Security contributions MHO: Graduated informal sector premium based on ability to pay Earmarked funds (NHIL & SSNIT) constitute over 90% of • total inflows Benefit package covers 95% of disease conditions Key Players in NHIS Architecture MINISTRY OF HEALTH (MOH) PROVIDERS (Public & Private) Provision of quality services 4 Stewardship (Policy & Regulation) Submission of Claims PURCHASER (NHIS) Payment of Claims Utilization of services SUBCRIBER Pays Premium Ensure provision of quality services ACTIVE MEMBERSHIP Your access to healthcare NHIS Payments v Cash payments 100% 90% 80% Your access to healthcare 70% 60% NHIS Payments 50% 40% 30% 20% 10% 0% 2006 2007 2008 2009 CASH Payments 2010 2011 2012 2013 Definition Your access to healthcare HEALTH CARE FRAUD • Health insurance fraud is described as an intentional act of deceiving, concealing, or misrepresenting information that results in health care benefits being paid to an individual or group. • Fraud can be committed by subscribers, providers and health insurance staff MOTIVATORS Motivators – Your access to healthcare TYPES OF FRAUD Types of fraud - Providers Your access to healthcare Billing for services not rendered Up-coding of services- DRG payments Double billing/Duplicate claims Misrepresentation of diagnosis Unbundling of services Unnecessary services Inappropriate referral for financial gain Insertion/Substitution of medicines Unauthorised co-payments Recycling old claims Unaccredited facilities submitting through accredited facilities Types of fraud - Subscribers Your access to healthcare Impersonation – a non-member using a member’s identity Ganging – all the family using one member’s card Provider shopping Illegal cash exchange for prescriptions Types of fraud- Health Insurance Staff Registering Your access to healthcare subscribers in exempt category thereby waiving premium Fast tracking membership thereby increasing adverse selection Passing fraudulent claims from providers for kickbacks PREVENTION/MITIGATION Ways to prevent/mitigate abuse Policy • Biometric registration • Payment mechanisms Pre-payment • Effective claims processing • Claims Processing Centres Postpayment • Claims verification • Compliance audit • Clinical audit Policy methods • Biometric registration • Biometric authentication at point of service • Capitation for Primary care services • Fee-for-service for medicines • DRG for specialist OPD , in-patient and surgical care Pre-payment methods Effective claims processing Claims Processing Centres - consolidation Membership – biometric authentication generates a Claims Check Code Treatment protocols – diagnoses linked to treatment Adherence to National Standard Treatment Guidelines Adherence to National Prescribing & Dispensing levels Electronic vetting business rules – logical & business rules Claims Processing Provider Payment Eligibility & Membership Paper claims E-vetting & E-adjudication CPC CLAIMS SOFTWARE G-DRG ICD-10 E-claims Treatment Protocols Statistical Data Comparing Claims Adjustments at CPC to Nationwide (2013) 12% 11% 10% 8% 6% 2% 0% 4% 3.50% 4% 2% 3% 2% 3% 4% 3% 2% 1% Post-payment methods • Claims verification – suspicious claims within 2 months of processing • Compliance audit – verify claims data – attendance, utilisation, • Clinical audit – assess quality of care, adherence to treatment protocols, appropriate staffing at facility Regional claims data 2012-June 2013 IPD & OPD Utilisation per active member 8.15 3.68 3.13 3.28 3.63 3.23 3.07 3.06 3.01 2.66 2.49 2.87 2.53 2.36 2.68 2.89 2.58 2.11 0.15 0.09 0.08 0.15 0.15 0.05 0.04 0.17 0.22 0.12 0.19 0.27 0.03 0.09 0.21 0.17 0.10 - WAY FORWARD Way forward - Incentives Encourage whistleblowers Early reimbursement for providers with clean claims. % tariff increase for adherence to treatment protocols Increased advocacy and sensitisation on the impact of fraud and abuse on the health insurance system Way forward - Deterrents Pass specific health insurance fraud laws making it a criminal offence e.g. USA Health Insurance Portability and Accountability of 1996 (HIPAA) Financial penalties above repayment of fraudulent payments Health care provider should lose its license with the regulatory bodies as well as disaccreditation by the insurer Public gazetting of fraud and abuse cases Conclusion • Health Insurance fraud is a global phenomenon • It cannot be eliminated entirely but can be minimised • Methods to prevent fraud is insurance scheme and country specific although there are general measures that can apply to all • There will always be loopholes in the medical scheme. • Each time a loophole is closed, another is found. • Insurers need to work with providers and members if the prevention methods are to be successful. 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