THE WELCH COMPANY
440 Davis Court #1602
San Francisco, CA 94111-2496
415 781 5700
rod@welchco.com
S U M M A R Y
DIARY: September 6, 2007 01:42 AM Thursday;
Rod Welch
Millie submits interim payment coinsurance UCSF clinical trial.
1...Summary/Objective
2...Call Medicare Explanation UCSF Invoices
3...UCSF Customers Must Call Medicare for Justification of UCSF Invoices
........Commend UCSF Doctor Rugo Infusion Staff Excellent Care
4...Complex Issues Requird Focused Review Patient History
5...Clinical Trial Provider Did Not Know Coinsurance Cost
6...Coinsurance Cost Clinical Trials Not Known by Kaiser or UCSF
..............
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CONTACTS
0202 - UCSF Medical Center O-00000875 0305
020201 - Mr. Robert Zvi Schwartz, MPH O-00000875 0305
020202 - Patient Financial Consultant
020204 - Patient Financial Services
SUBJECTS
Payment Medicare Coinsurance Interim Issued UCSF Justification Requi
4003 -
4003 - ..
4004 - Summary/Objective
4005 -
400501 - Follow up ref SDS 14 0000. ref SDS 13 0000.
400502 -
400503 - Millie submitted payment of $312 to UCSF for coinsurance, ref SDS 0
400504 - EB3P, based on UCSF promise to submit justification of charges for
400505 - doctor visits, ref SDS 0 EA5V, even though UCSF has previously
400506 - maintained patients in the clinical trial do now owe payment for
400507 - doctor visits. ref SDS 0 KC8S UCSF response by Doctor Rugo confirmed
400508 - that Kaiser made the referral for Millie's treatment in the clinical
400509 - trial at UCSF. The doctor further confirmed that UCSF did not know of
400510 - any out-of-pocket expenses for the patient. ref SDS 0 UK5M
400511 -
400512 -
400513 -
400514 -
400516 - ..
4006 -
4007 -
4008 - Progress
4009 -
400901 - Call Medicare Explanation UCSF Invoices
400902 - UCSF Customers Must Call Medicare for Justification of UCSF Invoices
400903 -
400904 - Follow up ref SDS 14 G15I.
400905 -
400906 - Millie submitted ref DIT 1 0001 to Doctor Rugo at UCSF with copies to
400907 - Jackie, Bob Schwartz in the accounting department, and to the primary
400908 - care physician at Kaiser. This letter submits interim payment for
400909 - coinsurance subject to justification, as set out in Millie's letter,
400910 - ref DIP 2 0001, submitted to Doctor Rugo a few days ago on 070904.
400911 - ref SDS 14 G15I
400913 - ..
400914 - Millie says to Doctor Rugo...
400915 -
400916 - 1. Following my letter, ref DIP 2 0001, to UCSF on September 4th,
400917 - ref SDS 14 G15I, Bob Schwartz in the UCSF accounting office
400918 - indicated in a telephone call that patients should contact
400919 - Medicare for explanation of UCSF charges for participation in
400920 - clinical trials. ref DIT 1 0001
400921 -
400922 - [...in another record today, Arlette submitted Kaiser
400923 - internal guidance on clinical trials for Senior
400924 - Advantage beneficieries, ref SDS 15 WC5S, who are
400925 - charged coinsurance; no amount is reported. ref SDS 15
400926 - WD3Y
400928 - ..
400929 - 2. Review shows coinsurance is widely disputed, illustrated by a
400930 - letter issued by the Cancer Leadership Council dated November
400931 - 30, 2006, ref DIT 1 WM62, and addressed to...
400932 -
400933 - http://www.cancerleadership.org/policy/clinic_medicare/061130.html
400934 -
400935 - [On 070917 Medicare statute Title 42 section 419.40
400936 - explains coinsurance minimum 20% for participation of
400937 - private insurance market coverage Medigap secondary,
400938 - supplemental insurance, ref SDS 18 4Q3I, which must pay
400939 - for coinsurance. ref SDS 18 IP8L Medigap must pay for
400940 - coinsurance on clinical trials. ref SDS 18 LN9W
400942 - ..
400943 - Kimberly Long
400944 - Medicare Coverage Advisory Committee
400945 - Centers for Medicare & Medicaid Services
400946 - Office of Clinical Standards and Quality,
400947 - Coverage and Analysis Group
400948 - 7500 Security Blvd. ? C1-09-06
400949 - Baltimore, Maryland 21233
400950 -
400951 - ...and stating in part...
400952 -
400953 - ...one of the challenges implementing the clinical trials
400954 - policy has been the lack of a reliable and consistent
400955 - definition of "routine costs" in clinical trials.
400956 - ref DIT 1 WM62
400958 - ..
400959 - We urge CMS to adjust payments to managed care plans to
400960 - reflect the costs that have been associated with the
400961 - National Coverage Decision on routine patient care costs
400962 - in clinical trials. This adjustment is necessary to ensure
400963 - that beneficiaries will have access to clinical trials
400964 - according to the terms of their managed care plans and not
400965 - as fee-for-service claims with 20% copayment. If efforts
400966 - to boost enrollment in managed care plans are successful,
400967 - this will become an even more serious problem. Therefore,
400968 - we urge immediate action to address it.
400970 - ..
400971 - 3. Another source says in part... ref DIT 1 WM8Q
400972 -
400973 - Kaiser Permanente Senior Advantage
400974 - Evidence of Coverage for
400975 - CITY OF SAN JOSE
400976 - Purchaser ID: 887 Contract: 4 Version: 46 EOC Number: 29
400977 - January 1, 2004 through December 31, 2004
400979 - ..
400980 - Special Note about Services Associated with Clinical Trials
400982 - ..
400983 - You should ask the clinical trial provider if the clinical
400984 - trial qualifies for Medicare payments and what Medicare
400985 - coinsurance and other out-of-pocket expenses you will have
400986 - to pay for related Services. ref DIT 1 004G
400988 - ..
400989 - Kaiser guidance for customers to ask clinical trial provider about
400990 - coinsurance and other costs, conflicts with a letter today reporting
400991 - the clinical trial director doesn't know anything about billings,
400992 - despite having investigated a lot of time to find out if Millie would
400993 - have to pay any out-of-pocket expenses, see below, ref SDS 0 I49K,
400994 - confirming understandings from meeting with Bob at UCSF on 070830.
400995 - ref SDS 12 WU5N
400996 -
400997 - [...in another record today, Kaiser's guidance
400998 - received from the Oncology Department says patients
400999 - who self-refer for treatment in clinical trials are
401000 - charged coinsurance, but do not say how much.
401001 - ref SDS 15 WD3Y
401003 - ..
401004 - Millie's letter to UCSF and Kaiser continues...
401005 -
401006 - 4. These sources support the record in this case that the clinical
401007 - trial provider asked the referring doctor about payment of
401008 - expenses and was notified that Kaiser would pay for expenses
401009 - not covered by the clinical trial. [reported on 061230,
401010 - ref SDS 2 3X6K, At no time was I informed that charges were
401011 - accumulating for services at UCSF beyond insurance premiums.
401012 - Specifically I was not told of coinsurance charges, and was
401013 - told there is no copayment charge on clinical trials. [see
401014 - report on 070130, ref SDS 5 KS6M and ref SDS 5 LC60,
401015 - ref DIT 1 WM85
401017 - ..
401018 - Clinical trial director confirms in a letter received later today that
401019 - Millie was not informed of coinsurance charges because UCSF did not
401020 - know of any grounds for billing the customer, and further notes this
401021 - case is very complicated. see below, ref SDS 0 UK5M
401022 -
401023 - [...in another record today, Arlette submitted Kaiser
401024 - internal guidance on clinical trials for Senior Advantage
401025 - beneficieries, ref SDS 15 WC5S, who are charged
401026 - coinsurance, ref SDS 15 WD3Y; no amount is reported.
401027 - ref SDS 15 WD3Y
401029 - ..
401030 - [On 070909 letter to Kaiser and to UCSF notifying charges
401031 - for coinsurance conflict with agreement on 061230 that
401032 - Kaiser would pay any costs not covered by clinical trial,
401033 - ref SDS 17 6O4U, and submit interim payment of copayments
401034 - for doctor visits, pending submission of justification for
401035 - charges when UCSF represents cost of doctor visits are paid
401036 - by the clinical trial. ref SDS 17 XM4F
401038 - ..
401039 - [On 070917 UCSF revised claim reduced to $1,500, annualized
401040 - to about $2K per year, ref SDS 18 WO4O, which more than
401041 - doubles copayment costs typically incurred for the work
401042 - involved. ref SDS 18 G68H
401044 - ..
401045 - If medical professionals don't know about coinsurance charges, this
401046 - indicates UCSF was satisfied that Kaiser would pay any costs not
401047 - covered by the trial. ref SDS 0 XK4Y
401049 - ..
401050 - Millie's letter to UCSF and Kaiser continues...
401051 -
401052 - 5. Bob indicated during the meeting on August 30th, that the
401053 - doctor was unable to notify the customer in this case about
401054 - charges, because nobody knows the amount until after UCSF
401055 - negotiates with Medicare and receives final payment for
401056 - billings. ref SDS 12 WU5N This appears somewhat conflicting
401057 - with the consistent pattern of charges in UCSF documentation,
401058 - shown below extracting coinsurance amounts. ref SDS 0 RD6I,
401059 - ref DIT 1 WM92
401060 -
401061 - [On 070917 UCSF revised claim reduced to $1,500, annualized
401062 - to about $2K per year, ref SDS 18 WO4O, which more than
401063 - doubles copayment costs typically incurred for the work
401064 - involved. ref SDS 18 G68H
401066 - ..
401067 - Millie's letter to UCSF and Kaiser continues...
401068 -
401069 - 6. My general understanding at this time is that UCSF seeks
401070 - recovery of "coinsurance" each time I visit with Doctor Rugo,
401071 - and/or her team for examination. Recently, the doctor
401072 - determined care has improved my condition sufficiently to
401073 - reduce meetings from twice to now just once a month.
401074 - ref DIT 1 WM96
401076 - ..
401077 - 7. Bob further indicated on August 30th that accounts in the UCSF
401078 - spreadsheet showing charges of $101 are for doctor visits
401079 - billed to Medicare. There was agreement to make interim
401080 - payment for doctor visits. ref SDS 12 V373 At this time the
401081 - amounts UCSF seeks to recover from me appear to vary from
401082 - $22.26 to 27.88. The basis for variable charges to the
401083 - customer of a fixed charge to Medicare has not been explained
401084 - by UCSF. [noted during the meeting at UCSF on 070830.
401085 - ref SDS 12 VT5W], ref DIT 1 WM97
401087 - ..
401088 - Implements Millie's letter on 070904 agreeing to make interim payment
401089 - of coinsurance and requesting UCSF to submit justification for this
401090 - charge. ref SDS 14 6R4W interim agreement to make partial payment on
401091 - coinsurance subject to justification by UCSF, and reimbursement upon
401092 - payment by Kaiser for Millie's care at UCSF. ref SDS 14 6R4W
401094 - ..
401095 - Millie's letter to UCSF continues...
401096 -
401097 - 8. Accordingly, as requested by Bob, today I will submit a
401098 - check to the UCSF Admissions Office on the ground floor at 1600
401099 - Divisadero, ref SDS 14 6R4W, and in the amount of $312.08 [...
401100 - subject to justification noted in Millie's letter on September
401101 - 4, 2007, ref SDS 14 6R4W...]. This amount was derived by
401102 - adding amounts that Bob checked with an ink pen on a
401103 - spreadsheet he prepared dated August 27, 2007 with the title...
401104 - ref DIT 1 WM98 [...and further subject to refund on payment to
401105 - UCSF by Kaiser for Millie's care, agreed with UCSF during
401106 - meeting on 070830 0807. ref SDS 12 FT6K and in particular -
401107 - ref SDS 12 QH6J...]
401109 - ..
401112 - Summary of Facility Accounts
401113 -
401114 - Doctor Visit Account Total Coinsurance
401115 -
401116 - 30-Jan-07 12571560 101.00 27.88
401117 - 01-Feb-07 12575738 101.00 22.26
401118 - 08-Feb-07 12588855 101.00 27.88
401119 - 01-Mar-07 12575761 101.00 22.26
401120 - 15-Mar-07 12720616 101.00 27.88
401121 - 29-Mar-07 12762558 101.00 27.88
401122 - 19-Apr-07 12880922 101.00 27.88
401123 - 26-Apr-07 12762597 101.00 22.26
401124 - 10-May-07 12762609 101.00 27.88
401125 - 24-May-07 12762615 101.00 27.88
401126 - 07-Jun-07 12997853 101.00 27.88
401127 - 21-Jun-07 12997859 101.00 22.26
401128 -
401129 - $312.08
401131 - ..
401132 - 9. I will be out of town for the next few weeks. Please submit
401133 - the amount I owe for meetings with Doctor Rugo since June 21,
401134 - so that I can bring the account up to date when I return. I
401135 - would like to make copayments on a pay-as-you-go basis at the
401136 - time services are performed, hopefully by credit card.
401137 - ref DIT 1 WM6F
401138 -
401139 - [On 070917 received revised UCSF billing spreadsheet
401140 - reducing claim by $8K down to $1,194.52. ref SDS 18
401141 - WP5I
401143 - ..
401144 - [On 070917 Medicare statute Title 42 section 419.40
401145 - explains coinsurance minimum 20% for participation in
401146 - clinical trials to advance medical science. ref SDS 18
401147 - 4Q3I
401149 - ..
401150 - [On 070927 Senior Advantage EOC section 2 Kaiser must
401151 - pay for prescribed care; relieves Millie of charges for
401152 - coinsurance under section 7, ref SDS 20 WS6M, and
401153 - established by 16 grounds, ref SDS 20 WU6M, aligns with
401154 - agreement in correspondence between Kaiser and UCSF on
401155 - 061230 for Kaiser to pay any costs not covered by the
401156 - clinical trial. ref SDS 2 3X6K
401158 - ..
401159 - [On 071128 Kaiser Appeals Committee approved payment
401160 - for Millie's care on referral to UCSF. ref SDS 30 JZ5R
401161 -
401162 -
401163 -
401164 -
401165 -
4012 -
SUBJECTS
Commend Excellent Professional Care UCSF Medical Center Love Working
6003 -
600401 - ..
600402 - Commend UCSF Doctor Rugo Infusion Staff Excellent Care
600403 -
600405 - ..
600406 - 10. I only add that everyone should understand that I love working
600407 - with Doctor Rugo, Brigid, Jackie, Catherine, Diane, Flora,
600408 - Nola. Everyone is competent, professional, and personable,
600409 - similar to my experience at Kaiser. ref DIT 1 WM6M
600410 -
600411 -
600412 -
600413 -
6005 -
SUBJECTS
Payment Doctor UCSF Knows Nothing Medicare Coinsurance Invested Hour
9203 -
9204 - 1127
920501 - ..
920502 - Complex Issues Requird Focused Review Patient History
920503 - Clinical Trial Provider Did Not Know Coinsurance Cost
920504 - Coinsurance Cost Clinical Trials Not Known by Kaiser or UCSF
920505 -
920506 - Millie received ref DRT 1 0001 from Doctor Rugo at UCSF responding to
920507 - Millie's letter this morning, ref DIT 1 0001, per above, and also to
920508 - the letter, ref DIP 2 0001, submitted to UCSF on 070904 that requested
920509 - support from the doctor. ref SDS 14 6Q7Y Copies went to Jackie, the
920510 - primary care physician at Kaiser, and Bob Schwartz in accounting at
920511 - UCSF. ref DRT 1 00W3
920512 -
920513 - 1. Please know that I have nothing to do with billing. As you
920514 - know, we spent hours trying to get help from Kaiser in
920515 - determining coverage, and all we ever found out was that
920516 - medicare would be responsible - but we never knew for how much.
920517 - I never had any more information than this, and of course this
920518 - is very complicated. ref DRT 1 0001
920520 - ..
920521 - Doctor Rugo's assessment that this case is very complicated aligns
920522 - with Bob Schwartz's analysis on 070823, ref SDS 10 RV6U, and so
920523 - requires careful review of case studies to understand causation, shown
920524 - in the record on 070830. ref SDS 12 LQ5I
920526 - ..
920527 - [On 070926 Karen at Kaiser assigned by primary care
920528 - physician to facilitate solution of clinical trial
920529 - payment issues notes Millie's case is very complex,
920530 - which requires careful support for team care doctor
920531 - patient partnership. ref SDS 19 QY5I
920533 - ..
920534 - [On 071010 UCSF tells patient to contact Medicare for
920535 - explanation of UCSF billings. ref SDS 22 OH7R
920537 - ..
920538 - [On 071011 UCSF accounting department refuses to explain
920539 - charges; Millie asks Doctor Rugo facilitate communications
920540 - to get the total amount UCSF claims Millie owes for
920541 - clinical trial services. ref SDS 23 K64W
920543 - ..
920544 - [On 071015 Millie has tried contacting Medicare for
920545 - explanation of UCSF invoices and was not successful,
920546 - similar to Doctor Rugo's experience in January. ref SDS 24
920547 - KH5Q
920549 - ..
920550 - [On 071018 0800 Doctor Rugo reports investigation indicates
920551 - Kaiser "cut Millie loose" to avoid responsibility for
920552 - providing standard of care which Kaiser ordered on referral
920553 - to UCSF. ref SDS 25 W23I
920555 - ..
920556 - Seems to confirm Millie was not notified of extra charges for
920557 - coinsurance, ref SDS 12 T247, and that this would be $10K, which is
920558 - 56% of the amount Medicare pays for treatment in the clinical trial,
920559 - reviewed on 070830. ref SDS 12 WP5I
920560 -
920561 - [...in another record today, Arlette submitted Kaiser
920562 - internal guidance on clinical trials for Senior Advantage
920563 - beneficieries, ref SDS 15 WC5S, who are charged
920564 - coinsurance; no amount is reported. ref SDS 15 WD3Y
920566 - ..
920567 - Case study on 070130 reports efforts by UCSF and Kaiser to start
920568 - Millie's treatment, ref SDS 6 2X6L, and aligns with the study on
920569 - 070830 from meeting with UCSF. ref SDS 12 LQ5I
920571 - ..
920572 - Doctor Rugo's letter continues...
920573 -
920574 - I would involve Kaiser in this discussion though, as you have
920575 - active insurance through them, and they referred you for
920576 - participation in the trial. I think the medicare coverage
920577 - rules here are very muddy, and relate to your relationship with
920578 - Kaiser. But I am no expert here, and really know nothing about
920579 - billing and coverage in this situation. ref DRT 1 0W6G
920581 - ..
920582 - UCSF confirms that Kaiser made the referral, as noted in Kaiser's
920583 - letter relating correspondence with UCSF on 061230, ref SDS 2 3X6K,
920584 - and confirmed by primary care physician on 070119. ref SDS 4 4R4M
920585 -
920586 - [On 070907 Doctor Johnson, primary care physician at
920587 - Kaiser, also reports not knowing anything about billings at
920588 - Kaiser. ref SDS 16 XH5H
920590 - ..
920591 - [On 070909 letter to Kaiser and to UCSF notifying charges
920592 - for coinsurance conflict with agreement on 061230 that
920593 - Kaiser would pay any costs not covered by clinical trial,
920594 - ref SDS 17 6O4U, and submit interim payment of copayments
920595 - for doctor visits, pending submission of justification for
920596 - charges when UCSF represents cost of doctor visits are paid
920597 - by the clinical trial. ref SDS 17 XM4F
920599 - ..
920600 - [On 070917 UCSF revised claim reduced to $1,500, annualized
920601 - to about $2K per year, ref SDS 18 WO4O, which more than
920602 - doubles copayment costs typically incurred for work
920603 - involved. ref SDS 18 G68H
920605 - ..
920606 - [On 071006 UCSF submits additional billings increasing
920607 - charges to about $20K per year; UCSF's actual claim very
920608 - difficult to determine. ref SDS 21 PRWW
920610 - ..
920611 - [On 071006 CMS made referral to Paula in Kaiser Member
920612 - Relations group; Paula seems very capable addressing
920613 - complex issues in this case. ref SDS 21 Q998
920615 - ..
920616 - [On 071011 Millie requests UCSF explain confusing billings,
920617 - citing Doctor Rugo's comment that requirements are "very
920618 - muddy." ref SDS 23 K65V
920620 - ..
920621 - [On 071018 0800 Doctor Rugo reports investigation indicates
920622 - Kaiser "cut Millie loose" to avoid responsibility for
920623 - providing standard of care which Kaiser ordered on referral
920624 - to UCSF. ref SDS 25 W23I
920626 - ..
920627 - [On 071026 UCSF responds, ref SDS 26 K49J, and demands
920628 - payment of its claim against Millie within 1 week.
920629 - ref SDS 26 SU5V
920631 - ..
920632 - [On 071027 patient requests meeting so UCSF can present
920633 - claim, and explain charges. ref SDS 27 CG6H
920635 - ..
920636 - [On 071029 UCSF refuses to meet; claims suffering from
920637 - delay "stringing out payments. ref SDS 28 6N6K
920639 - ..
920640 - [On 071031 UCSF notice treatment for cancer ordered by
920641 - Kaiser will be terminated, ref SDS 29 KM8J; further notice
920642 - UCSF making referral to collection agency for payment of
920643 - $202.65 on Kaiser referral. ref SDS 29 KK4I
920645 - ..
920646 - [On 071128 Kaiser Appeals Committee approved payment for
920647 - Millie's care on referral to UCSF. ref SDS 30 JZ5R
920649 - ..
920650 - Doctor Rugo's letter continues...
920651 -
920652 - 2. As we discussed initially, there was some risk involved as
920653 - there is no way to get pre-approval from medicare. ref DRT 1
920654 - BW6N
920656 - ..
920657 - 3. Bob, any thoughts on this and who the Buck's could contact
920658 - through Kaiser? ref DRT 1 MW7H
920660 - ..
920661 - If medical professionals don't know about extra charges, this supports
920662 - Millie's reliance on Kaiser paying any costs not covered by the trial,
920663 - as agreed between Kaiser and UCSF in correspondence on 061230.
920664 - ref SDS 2 3X6K
920665 -
920666 -
920667 -
920668 -
920669 -
920670 -
920671 -
920672 -
920673 -
920674 -
920675 -
920676 -
920677 -
9207 -