Purpose:

Providence Health & Services - Washington/Montana hospitals are united in providing care based on the following principles:

• At Providence, we provide care to all those in need regardless of their ability to pay. This is an important part of our Mission.

• Each hospital will have financial assistance procedures that are consistent with the Mission and Values of Providence Health & Services. These procedures, which should be broadly communicated, should reflect a commitment to provide financial assistance to patients who cannot pay for part or all of the care they receive.

• Our Financial Assistance policies must maintain a careful balance between the need for fiscal stewardship and our bias toward the charitable Providence mission.

• All patients should be treated fairly, with dignity, compassion and respect.

• This policy will apply to Providence Health & Services staff, providers and agents and require adherence to its standards and scope of practices.

Policy:

It is the policy of Providence Health & Services - Washington/Montana to promote the health and well being of the people in the communities that we serve. With the foundation and commitment of our Christian Heritage and values of our mission, we will provide a comprehensive continuum of services in collaboration with partners who share the same vision and ideals.

It is the responsibility of the Providence Health & Services service facility to respond to all patient requests for charity eligibility during any one or more patient business interactions; namely pre-registration, registration, and discharge; or at any other time the facility staff encounters information detailing the patient's financial need. Charity will be re-screened throughout the revenue cycle when account events trigger review.

It is the responsibility of the patient to actively participate in the financial assistance screening process.

Charity approval will affect all accounts the approved guarantor is responsible for. The approved charity percentage will be applied to all existing accounts with debit balances. Any patient credit balance created by applying the charity percentage will be refunded to the guarantor within thirty (30) days of receiving the charity care designation. Accounts may also be returned from Bad Debt status if financial circumstances warrant and charity may be applied. Patients requesting charity may be required to apply for Medicaid benefits. All charity accounts for the previous quarter will be reviewed for Medicaid eligibility, if eligibility was established for dates of service covered under Charity, those Charity adjustments will be reversed and the services will be billed to Medicaid for processing.

Each Providence Health & Services hospital shall develop a set of Charity Care assessment guidelines to supplement this policy. These guidelines will consider all applicable state and federal laws as well as detail the following:

• Pre-Screen triggers for admitting and pre-registration staff.

• Non-Covered Services (Elective Cosmetic services, etc.)

• Procedures for Information Distribution (signage placement, pamphlet distribution, application distribution, etc.)

• Full Charity care sponsorship for those at or below 200% of the federal poverty standard)

• Other self-pay options for patients denied charity based on income. (Payment plans)

Elegibility Requirements:

All guarantors, with family income equal to or below two hundred percent of the federal poverty standard, adjusted for family size, shall be determined to be indigent persons qualifying for charity sponsorship for the full amount of hospital charges related to appropriate hospital-based medical services that are not covered by private or public third-party sponsorship.

All guarantors, with family income between two hundred one and four hundred percent of the federal poverty standard, adjusted for family size, shall be determined to be indigent persons qualifying for discounts from charges related to appropriate hospital-based medical services in accordance with the sliding fee schedule and policies regarding individual financial circumstances based on the below criteria:

• Eligibility shall be based on financial need at the time of application by comparing total family income1 with the current Federal Poverty guidelines. If a family's income is greater than 100% of the federal poverty guideline, family assets, other than exempt assets listed below, may be considered as a source of payment.

• Exempt assets (based on Medicare exempted assets) listed below should not be added to family worth for charity review:

  • Family's principal residence.

  • Necessary motor vehicle(s). (Required for employment; required for access to treatment; or modified for operation or transport of a disabled person.)

  • Personal effects and household goods.

  • Resources necessary for self-support. All resources of both spouses are considered together.

• Charity will be assigned using the most recently published federal poverty standards, and evaluated on the Adjusted Family Income as explained above for those above 201% of such standards.

• Documentation will be requested and in most cases will be required to establish eligibility for Charity care; however the absence of documentation in certain circumstances deemed reasonable and understandable by the provider's billing staff (e.g., homeless person) will not necessarily require a Charity denial.

• Department management or senior management may approve charity care in extenuating circumstances.

Charity Percentage Sliding Scale:

A sliding scale fee schedule will be used to determine charity balance percentages. The minimum charity approval begins with incomes at 400% of the federal poverty level and continues to increase discounts as the family income reaches 201% of the federal poverty level. As indicated above, any guarantor at or below 200% of the federal poverty level, as adjusted for family size, will be entitled to charity sponsorship for the full amount of hospital charges related to appropriate hospital-based medical services that are not covered by private or public third-party sponsorship

Evaluation Process:

The process for determining which patients qualify for charity care will include:

• Exhausted or not eligible for any third-party payment sources

  • All possible insurance payors have been billed.

  • Medicaid benefits denied or Family Planning Only benefits assigned.

  • Patient is not eligible for Medicare benefits.

• Making an initial determination whether the patient is eligible for charity care, prior to initiating any collection efforts, assuming the patient cooperates with the organization's attempt to make the determination;

• Making the initial determination prior to service, at the time of service, or as soon as practical after service has been provided to the patient;

• Making reasonable attempts to determine if a third-party payor or sponsor may pay some or all of the charges;

• Providing all patients who have been initially determined to meet the criteria for charity care with at least fourteen (14) business days, or such time as may be reasonably necessary given the patient's medical condition, to provide any required documentation before the organization reaches a final decision whether the patient is eligible for charity care. The organization will notify the patient of its final determination within fourteen (14) business days of receiving the necessary documentation;

• Not imposing any unreasonable burden upon the patient to provide relevant information when considering the application for charity care. The organization may require the patient to validate the accuracy of any information provided. Any of the following documents shall be considered sufficient evidence upon which to base a determination of eligibility for charity care: all medical bills, last 3 months of pay stubs, current bank statements and/or income tax return from the previous year, W-2 statements from the previous year, unemployment compensation forms, forms approving or denying Medicaid or written statements from employers or welfare agencies;

• Notifying the patient of the organization's decision, (approval or denial), the grounds for reaching the decision, and the process for appealing the decision if the organization deems the patient ineligible for charity care;

• If charity care is denied, providing the patient with thirty (30) calendar days within which to appeal the decision, correct any deficiencies in documentation, or request a review of the denial. Within the first thirty (30) days following a denial, the organization may not refer the patient's account to an external collection agency. If no request for review is made during that thirty (30) day period, the organization may then initiate collection activities. If the organization has initiated collection activities and then discovers a request for review has been made, the organization will stop collection efforts until the review is completed;

• Allowing a patient to apply for charity care at any point from pre-admission to final payment of the bill, recognizing that a patient's ability to pay over an extended period may be substantially altered due to illness or financial hardship, resulting in a need for charity services. If the change in financial status is temporary, the organization can choose to suspend payments temporarily rather than initiate charity care.

Communication to the Public:

• Each hospital should post notices regarding the availability of financial assistance to low-income uninsured patients. These notices should be posted in visible locations throughout the hospital such as admitting/registration, billing office, emergency department and other outpatient settings.

• Every posted notice regarding financial assistance policies should contain brief instructions on how to apply for financial assistance or a discounted payment. The notices also should include a contact telephone number that a patient or family member can call to obtain more information.

• Hospitals should ensure that appropriate staff members are knowledgeable about the existence of the hospital's financial assistance policies. Training should be provided to staff members (i.e., billing office, financial department, etc.) who directly interact with patients regarding their hospital bills.

• When communicating to patients regarding their financial assistance policies, hospitals should attempt to do so in the primary language of the patient, or his/her family, if reasonably possible, and in a manner consistent with all applicable federal and state laws and regulations.

• Hospitals should share their financial assistance policies with appropriate community health and human services agencies and other organizations that assist such patients.

Billing and Collection Practices:

• Hospitals will have written policies about when and under whose authority patient debt is advanced for collection, and should use their best efforts to ensure that patient accounts are processed fairly and consistently.

• Hospitals should ensure that practices to be used by their outside (non-hospital) collection agencies will conform to the standards set forth in this policy, and should obtain written commitments from such agencies that they will adhere to those standards. Hospitals should also conduct an assessment of each collection agency's adherence to the policy. Such assessment should be conducted at least annually.

• At time of billing, hospitals shall provide to all low-income uninsured patients the same information concerning services and charges provided to all other patients who receive care at the hospital.

• When sending a bill to a patient, hospitals should include a) a statement that indicates that if the patient meets certain income requirements the patient may be eligible for a government-sponsored program or for financial assistance from the hospital; and b) a statement that provides the patient with the name and telephone number of a hospital employee or office from whom or which the patient may obtain information about the hospital's financial assistance policies for patients and how to apply for such assistance.

• Any patient seeking financial assistance from the hospital (or the patient's legal representative) shall provide the hospital with information concerning health benefits coverage, financial status (i.e. income, assets) and any other information that is necessary for the hospital to make a determination regarding the patient's status relative to the hospital's financial assistance policy, discounted payment policy, or eligibility for government-sponsored programs.

• For patients who have an application pending determination for either government-sponsored coverage or for the hospital's own financial assistance program, a hospital should not knowingly send that patient's bill to a collection agency.

• Eligibility for financial assistance will be determined as closely as possible to the date of service.

CONSEQUENCES:

Violation of this policy may constitute grounds for immediate disciplinary action, up to and including termination of employment, service, or association with PH&S. Violation of the laws and regulations upon which this policy is based may result in possible civil and/or criminal action