Billing and Collections Policy

Transcription

1 Billing and Cllectins Plicy Objective Created: 3/13/2014 Last Revised: 1/15/2015/KG Reviewed: Kim Gre Clumbus Reginal Healthcare System seeks t allcate available financial resurces effectively t reduce the cst f health care services fr thse patients within the cmmunity, wh are mst in need, cnsistent with their respective legal bligatins. This plicy recgnizes the financial resurces f Clumbus Reginal Healthcare System a r e limited; and that Clumbus Reginal Healthcare System has a fiduciary respnsibility t bill and cllect apprpriately fr patient services. Clumbus Reginal Healthcare System d e s nt discriminate n the basis f race, clr, natinal rigin, citizenship, alienage, religin, creed, sex, sexual preference, age, r disability in their plicies, r in the applicatin f their plicies, including the acquisitin and verificatin f financial infrmatin, preadmissin r pretreatment depsits, payment plans, deferred r rejected admissins, eligibility status determinatins, r in their billing and cllectin practices. Clumbus Reginal Healthcare System recgnizes the cst f necessary health care services can impse a financial burden n patients wh are uninsured r underinsured and has acted t lessen that burden fr patients. Clumbus Reginal Healthcare System als recgnizes the billing and cllectin prcess is cmplex and has implemented prcedures t make the prcess mre understandable fr patients; and t infrm patients abut discunt and financial assistance ptins. Cnsistent with these cmmitments Clumbus Reginal Healthcare System maintains a billing and cllectin plicy that cmplies with applicable state and federal laws and regulatins. This plicy describes the financial assistance and discunt prgrams as well as the billing, payment and cllectin prcesses applicable t services prvided t patients. The plicy addresses nly thse prgrams and prcesses applicable t patients (and patient guarantrs) and nt third party payers. The plicy is develped t ensure cmpliance with applicable regulatins required under (1) the Centers fr Medicare & Medicaid Services Medicare Bad Debt Requirements (42 CFR ), (2) the Medicare Prvider Reimbursement Manual (Part I, Chapter 3), and (3) the Internal Revenue Cde Sectin 50 I (r). Definitins Financial Assistance Prgram: A prgram intended t assist lw-incme patients wh d nt therwise have the ability t pay fr their health care services. Such assistance shuld take int accunt each individual's ability t cntribute t the cst f his r her care. Cnsideratin is als given t patients wh have exhausted their insurance benefits and/r wh exceed financial eligibility criteria but face extrardinary medical csts. A financial assistance prgram is nt a substitute fr emplyer-spnsred, individually purchased insurance prgrams, r publically available financial assistance Medically Necessary Service: A service that is reasnably expected t prevent, diagnse, prevent the wrsening f, alleviate, crrect, r cure cnditins that endanger life, cause suffering r pain, cause physical defrmity r malfunctin, threaten t cause r t aggravate a handicap, r result in illness r Page 1 f 11

2 infirmity. Medically necessary services shall include inpatient and utpatient services as mandated under Title XIX f the Federal Scial Security Act. Elective: Thse services that, in the pinin f a physician, are nt medically necessary r can be safely pstpned. Emergency Care: Immediate care which is necessary in the pinin f a physician t prevent putting the patient s health in serius jepardy, serius impairment t bdily functins r serius dysfunctin f any rgans r bdy parts. Nn-Cvered Services: Nn-medical services, such as scial, educatinal, and vcatinal services; csmetic surgery; self- administered medicatins. Primary Care: Primary care cnsists f health care services custmarily prvided by general practitiners, family practitiners, general internists, general pediatricians, and primary care nurse practitiners r physician assistants, fr purpses f preventin, diagnsis, r treatment f acute r chrnic disease r injury, but excludes ancillary services and maternity care services. Prmpt Pay Discunt: A discunt prvided n a patient s ut-f-pcket expenses when such expenses are paid within a pre-determined number f days frm the date f initial statement Estimate f Patient Liability: An expected ut-f-pcket dllar amunt prvided t the patient based n the patient s specific prcedure, attending physician and insurance plan. An estimate shuld nt be interpreted as an exact r final cst. Bad Debt: Accunts that have been determined t be uncllectible because the patient has been unwilling t pay fr their medical care. Husehld Financial Incme: Husehld Financial Incme as measured against annual Federal Pverty Guidelines includes, but is nt limited t the fllwing: Annual husehld pre-tax jb earnings Unemplyment cmpensatin Wrkers Cmpensatin Scial Security and Supplemental Security Incme Veteran s payments Pensin r retirement incme Other applicable incme t include, but nt limited t, rents, alimny, child supprt, and any ther miscellaneus surce Third Party Insurers: Any party insuring payment n behalf f a patient t include but nt limited t: insurance cmpanies, Wrkers Cmpensatin, gvernmental plans such as Medicare and Medicaid, State/Federal Agency plans, Victim s Assistance, etc., r third-party liability resulting frm autmbile r ther accidents. Uninsured: Patients wh are nt cvered under an insurance health plan, Wrkers Cmpensatin, gvernmental plans such as Medicare and Medicaid, State/Federal Agency plans, Victim s Assistance, etc., r third-party liability resulting frm autmbile r ther accidents. Underinsured: Patients cvered by a surce f third party funding, but at risk f high ut-f-pcket expenditures due t their plan benefits package. This may include, but is nt limited t, high deductible plans, high cinsurance/cpay plans, lw per diem plicies, etc.>> Delivery f Health Care Services Clumbus Reginal Healthcare System evaluates the delivery f health care services fr all patients wh present fr services In the Emergency Department regardless f their ability t pay. The urgency f treatment assciated with each patient's presenting clinical symptms will be determined by a medical prfessinal in accrdance with lcal standards f practice, natinal and state clinical standards f care, and the hspital medical staff plicies and prcedures. It is imprtant t nte that classificatin f patients medical cnditin is fr clinical management purpses nly, and such classificatins are intended fr addressing the rder in which physicians shuld see patients based n their presenting clinical symptms. These classificatins d nt reflect medical evaluatin f the patient's medical cnditin reflected in final diagnsis. Clumbus Reginal Healthcare System als cmplies with the federal Emergency Medical Treatment and Active Labr Act (EMTALA) by cnducting a medical screening examinatin t determine whether an emergency medical cnditin exists when required by that law. (Refer T Inter-Hspital Facility Transfer) Page 2 f 11

3 Clinical and financial cnsideratins as well as the benefits ffered by private insurance r gvernment prgrams may affect the timing f, r access t, nn-emergent r nn-urgent health care services (i.e., elective services). Such services may be delayed r deferred based n cnsultatin with the hspital's clinical staff and, if necessary, and if s available, the patient's healthcare prvider. Clumbus Reginal Healthcare System may decline t prvide a patient with nn-emergent, nn urgent services in thse cases when a payment surce cannt be identified. Fr patients cvered by private insurance r gvernment prgrams, patient chices related t the delivery f, and access t, care are ften defined in the insurance plan's r the gvernment prgram's cverage guidelines. Fr patients wh are uninsured r underinsured, Clumbus Reginal Healthcare System will wrk with patients t find a Financial Assistance Prgram that may cver sme r all f their unpaid hspital bill(s). Fr thse patients with private insurance, Clumbus Reginal Healthcare System must wrk thrugh the patient and the insurer t identify what services may be cvered by the patient's insurance plicy. Fr patients seeking nn-emergent and nn-urgent services, it is the patient s respnsibility t knw what services will be cvered prir t seeking care. A. Emergency and Urgent Care Services Any patient wh cmes t Clumbus Reginal Healthcare System will be evaluated as t the level f emergency r urgent care services withut regard t the patient s identificatin, insurance cverage, r ability t pay. 1. Emergency Level Services include: Medically Necessary services prvided after the nset f a medical cnditin, whether physical r mental, manifesting itself by symptms f sufficient severity including severe pain, that the absence f prmpt medical attentin culd reasnably be expected by a prudent laypersn wh pssesses an average knwledge f health and medicine t result in placing the health f the persn r anther persn in serius jepardy, serius impairment t bdy functin r serius dysfunctin f anybdy rgan r part r, with respect t a pregnant wman, as further defined in sectin 1867(e) (1) (B) f the Scial Security Act, 42 U.S.C. 1295dd (e) (l) (B). A medical screening examinatin and any subsequent treatment fr an existing emergency medical cnditin r any ther such service rendered t the extent required pursuant t the federal EMTALA (42 USC 1395(dd) qualifies as an Emergency Level Service. 2. Urgent Care Services include: Medically Necessary services prvided after sudden nset f a medical cnditin, whether physical r mental, manifesting itself by acute symptms f sufficient severity (including severe pain) that a prudent laypersn wuld believe that the absence f medical attentin within 24 hurs culd reasnably expect t result in: placing the patient s health in jepardy, impairment t bdily functin, r dysfunctin f any bdily rgan r part. Urgent Care Services are prvided fr cnditins that are nt life threatening and d nt pse a high risk f serius damage t an individual's health, but prmpt medical services are needed. 3. EMTALA Level Requirements: In accrdance with federal requirements, EMTALA is triggered fr anyne wh cmes t the hspital prperty requesting examinatin r treatment f an emergency level service (emergency medical cnditin), r wh enters the emergency department requesting examinatin r treatment fr a medical cnditin. Mst cmmnly, unscheduled persns present themselves at the emergency department. Hwever, unscheduled persns requesting services fr an emergency medical cnditin while presenting at anther inpatient unit, clinic, r ther ancillary area may als be subject t an emergency medical screening examinatin in accrdance with EMTALA. Examinatin and treatment fr emergency medical cnditins r any such ther service rendered t the extent required under EMTALA, will be prvided t the patient and will qualify as emergency care. The determinatin that there is an emergency medical cnditin is made by the Page 3 f 11

4 examining physician r ther qualified medical persnnel f the hspital as dcumented in the medical recrd. The determinatin that there is an urgent r primary medical cnditin is als made by the examining physician r ther qualified medical persnnel f the hspital as dcumented in the medical recrd. B. Nn-Emergent, Nn-Urgent Services: Fr patients wh either (1) arrive t Clumbus Reginal Healthcare System seeking nn-emergent r nn-urgent level care r (2) seek additinal care fllwing stabilizatin f an emergency medical cnditin, Clumbus Reginal Healthcare System may prvide elective services after cnsulting with clinical staff and reviewing the patient's cverage ptins. Elective Services can be medically necessary services that d nt meet the definitin f Emergency Level services r Urgent Care Services d e f i n e d abve. Typically, these services are either primary care services r medical prcedures scheduled in advance by the patient r by their health care prvider (hspital, physician ffice, ther). Cllectin f Infrmatin n Patient Cverage and Financial Resurces A. Patient Obligatins: Prir t the delivery f any health care services (except fr cases requiring Emergency Level Services r Urgent Care services), the patient is expected t prvide timely and accurate infrmatin n their insurance status, demgraphic infrmatin, changes t their family incme r insurance status, and infrmatin n any deductibles r c-payments that are wed based n their existing insurance r financial prgram s payment bligatins. The detailed infrmatin may include: 1. Full name, address, telephne number, date f birth, scial security number (if available), current health insurance cverage ptins, citizenship, residency infrmatin, and the patient's applicable financial resurces that may be used t pay their bill; 2. Full name f the patient's guarantr, their address, telephne number, date f birth, scial security number (if available), current health insurance cverage ptins, and their applicable financial resurces that may be used t pay fr the patient's bill; and Other resurces that may be used t pay their bill, including ther insurance prgrams, mtr vehicle r hmewners insurance plicies if the treatment was due t an accident, wrker's cmpensatin prgrams, and student insurance plicies, amng thers. It is ultimately the patient s bligatin t keep track f and timely pay their unpaid hspital bill, including any existing c-payments and deductibles. The patient is further required t infrm either his/her current health insurer (if insured) r the gvernment agency that determined the patient s eligibility status in a gvernment prgram (if participating) f any changes in family incme r insurance status. B. Hspital Obligatins: Clumbus Reginal Healthcare System will make all reasnable and diligent effrts t cllect the patient's insurance and ther infrmatin t verify cverage fr the health care services t be prvided. These effrts may ccur during the scheduling f services, during pre-registratin, while the patient is admitted in the hspital, upn discharge, r during the cllectin prcess which may ccur fr a reasnable time fllwing discharge. This infrmatin may be btained prir t the delivery f any nn-emergent and nn-urgent health care services (i.e., elective prcedures as defined in this Page 4 f 11

5 billing and cllectin plicy). Clumbus Reginal Healthcare System will defer any attempt t btain this infrmatin during the delivery f any EMTALA level emergency r urgent care services, if the prcess t btain this infrmatin will delay r interfere with either the medical screening examinatin r the services undertaken t stabilize an emergency medical cnditin. If the patient r guarantr/guardian is unable t prvide the infrmatin needed, and the patient cnsents, Clumbus Reginal Healthcare System will make reasnable effrts t cntact relatives, friends, guarantr/guardian, and the third party fr additinal infrmatin. Clumbus Reginal Healthcare System maintains all infrmatin in accrdance with applicable federal and state privacy and security laws. Patient Ntice f Availability f Financial Assistance A. General Principles Clumbus Reginal Healthcare System is cmmitted t ensuring patients r prspective patients in the cmmunity are aware f the availability f Financial Assistance Prgrams. A cpy f financial assistance plicy and this billing and cllectin plicy is psted n the Clumbus Reginal Healthcare System website. T assist uninsured and underinsured patients in identif ying available and apprpriate financial assistance prgrams, the hspital will prvide a general ntice f the availability f prgrams in each billing statement as well as general ntices psted thrughut the hspital. B. Signage Signs, psted in cnspicuus, lcatins will ntify patients f the availability f Financial Assistance Prgrams in bth English and any ther language which represents 10% f ppulatin service area. Signs will be large enugh t be clearly visible and legible fr patients in the hspital's service area. C. Ntificatin Practices 1. Clumbus Reginal Healthcare System w i l l include a ntice abut the availability f financial assistance in each billing statement 2. Clumbus Reginal Healthcare System w i l l include a ntice abut the availability f financial assistance in all written cllectin actins. Plicy Clumbus Reginal Healthcare System generally expects patients r their third party payers t pay in full fr services prvided. C l u m b u s R e g i n a l H e a l t h c a r e S y s t e m w i l l bill third party payers in accrdance with the requirements f applicable law, cntracts with third party payers r applicable billing guidelines. Patients are als respnsible fr charges that are nt paid by a third party payer within a reasnable time frame r fr any balances that exist after payment by the third party payer. Patients wh seek services (ther than emergency services) may be requested t pay in advance fr services that will nt be cvered by third party payers, including c payments and deductibles related t cvered services. The patient's failure t pay r make satisfactry financial arrangements will render the accunt delinquent. The hspital reserves the right t take cllectin actins as permitted by law cncerning balances due frm either the patient r third party insurers. Page 5 f 11

6 Pre Service Clumbus Reginal Healthcare System is cmmitted t helping patients understand and manage the cst f services they receive befre thse services are delivered. T help patients prepare fr and manage the cst f care they receive, a registratin team member may perfrm pre-service review steps t ensure all infrmatin cllected is accurate. Accurate infrmatin is critical t avid billing issues and t ensure insurance benefits can be accessed t minimize ut-f-pcket expenses. Befre nn-emergency services are delivered r after emergency cnditins have been stabilized, the registratin team may perfrm the fllwing activities: Validate and Prtect Patient Identity t prtect medical and financial infrmatin, Clumbus Reginal Healthcare System may use cmmercially available data surces t validate the accuracy f names and addresses. T receive nn-emergency services, Clumbus Reginal Healthcare System may ask the patient r guarantr fr pht ID and may include a cpy f yur pht ID with yur medical recrd. Verify Insurance Benefits based n infrmatin prvided by patients and guarantrs, Clumbus Reginal Healthcare System may use ur data systems t cmmunicate with insurance cmpanies t verify eligibility and benefits. If insurance infrmatin is nt prvided, Clumbus Reginal Healthcare System may check with the majr insurance cmpanies and applicable state Medicaid prgram t check fr cverage. Verifies Medical Necessity nt all services are cvered by insurance plicies. T minimize cst assciated with services nt cvered by insurance Clumbus Reginal Healthcare System may verify the apprpriateness f per-service diagnsis and prcedure cdes s that patients can make an infrmed decisin abut receiving the recmmended services. Obtain Prir Authrizatins If the services t be prvided require prir authrizatin frm an insurance cmpany, Clumbus Reginal Healthcare System will attempt t secure that authrizatin frm yur insurance cmpany. Each patient is respnsible fr making sure his/her insurance benefits will cver the cst f services t be prvided. If Clumbus Reginal Healthcare System is unable t btain prper authrizatin, patients may be respnsible fr the cst f services delivered. Identify Open Bad Debt Accunts if the patient r guarantr has previusly unpaid accunts that have nt been enrlled in a payment plan, thse balances may be required t be paid in full r paid in part and enrlled in ur payment plan. Prduce an Estimate f Patient Liability t help patients make infrmed health care purchasing decisins, an estimate f service csts and patient liabilities may be prvided. Clumbus Reginal Healthcare System will use all data described in this sectin t estimate ut-f-pcket expenses based n specific insurance benefits, prir authrizatin requirements and any pen prir accunts. In the event that ur registratin team is unable t identify cverage fr services t be prvided, patients may be referred t a financial cunselr. Patients will be requested t pay all r a prtin f the estimated c-pays, c-insurance amunts and/r deductible amunts. If the patient is uninsured, a percentage f grss charges will be requested Our pre-service financial clearance prcess is designed t help patient s manage unexpected csts assciated with health care services. Clumbus Reginal Healthcare System als prvides payment ptins t help patients manage balances within their budgets. Financial Assistance Prgrams Clumbus Reginal Healthcare System patients may be eligible fr free r reduced cst f health care services thrugh varius State Prgrams, r the Hspital Financial Assistance Prgram based n the patient s financial circumstances. Refer t PFS Financial Assistance Plicy fr mre detail. Page 6 f 11

7 Patients are advised that physician services (whether r nt prvided in a hspital setting) are generally nt subject t the Hspital Financial Assistance Prgram. Physicians r physician grups may have their wn plicies fr ffering discunts r prviding free care. Clumbus Reginal Healthcare System encurages patients t discuss the availability f discunts r free care directly with their physicians r with a billing representative. Hardship Settlement This prgram is designed t assist Nrth Carlina and Suth Carlina residents wh have had a catastrphic medical event regardless f their insurance cverage that has resulted in very large hspital bills in cmparisn t their financial resurces. Patients wh have incurred a balance after all insurance, r third-party payments that is greater than 20% f their ttal husehld financial resurces may be eligible fr a Hardship Settlement discunt. Patients seeking a hardship settlement shuld inquire abut this prgram by calling the custmer service department after receiving their first balance due statement. Billing and Cllectin Prcess A. General Clumbus Reginal Healthcare System uses the same reasnable effrts and fllws the same reasnable prcess fr cllecting amunts due fr services prvided t all patients, including insured, underinsured r uninsured patients. Cllectin activities may ccur during the pre-registratin prcess and will cntinue until accunt reslutin, a determinatin the accunt is uncllectible, r determinatin f eligibility fr financial assistance. The cllectin prcess may include the use f depsits, the implementatin f payment plans r discretinary settlements. The cllectin prcess may invlve the use f utside cllectin agencies which may include reprting the utstanding balance t credit reprting agencies. The cllectin prcess is dcumented in the patient s accunt files accessible t the hspital and its business assciates invlved in the cllectins prcess. (Cllectin will nt, hwever, be pursued against patients wh fall within ppulatins exempt frm cllectin actin by law.) Clumbus Reginal Healthcare System will make reasnable and diligent effrts t investigate whether a third party resurce may be respnsible fr the services prvided by the hspital, including but nt limited t: (1) a mtr vehicle r hme wner's liability plicy, (2) general accident r persnal injury prtectin plicies, (3) wrker's cmpensatin prgrams, (4) student insurance plicies. In accrdance with applicable state regulatins r the insurance cntract, fr any claim where reasnable and diligent effrts resulted in a recvery n the health care claim billed t a private insurer r public prgram, Clumbus Reginal Healthcare System will reprt the recvery and ffset it against the claim paid by the private insurer r public prgram. If Clumbus Reginal Healthcare System has prir knwledge and is legally able, it will attempt t secure assignment n a patient's right t third party cverage (r settlement) n services prvided due t an accident. Refer t Clumbus Reginal Healthcare System verpayment and r refund/credit balance plicy. B. Cllectin Ntices Clumbus Reginal Healthcare System has a fiduciary duty t seek payment fr services it has prvided frm patients wh are deemed able t pay. Clumbus Reginal Healthcare System reserves the right t utilize utside vendrs t assist the facility and patients regarding balances due, prcess payment plans, etc. When a balance is wed by the patient, the payment is cnsidered Self-Pay and payment in full is expected. An accunt is determined t be Self-Pay if: There is n insurance n recrd. All expected payments frm the insurance carriers, Medicare and ther third party payers have been paid. A patient has nt respnded timely t requests fr infrmatin/dcumentatin needed t determine eligibility under Financial Assistance Plicies. Page 7 f 11

8 Patient des nt prvide infrmatin requested frm third party insurers t prcess claims All self-pay accunts prcess thrugh specific statement cycles. Because f the inherent delays and ther issues with Medicaid eligibility prcesses, Clumbus Reginal Healthcare System may perfrm Medicaid eligibility checks n all Self-Pay accunts after discharge. If Medicaid cverage is identified, the accunt will be reclassified t Medicaid frm Self-Pay and billed t Medicaid. All Self-Pay accunts will be sent a minimum f three statements with the last r next t the last cntact ntifying the patient that if the bill remains unpaid, in 30 days they will be referred fr additinal cllectin actins. On any Self-Pay statement, ntificatin is present that an itemized bill can be requested by cntacting ur Custmer Service call center. All cmmunicatins prir t bad debt placement, including verbal cmmunicatins by third party cllectrs, include ntificatin f the availability f Financial Assistance. This prcess may be supplemented by ther ntificatin methds that cnstitute a genuine effrt t cntact the party respnsible fr the bligatin, including, fr example, telephne calls, cllectin letters, persnal cntact ntices, and cmputer ntificatins. Fr statements that have been returned as undeliverable, reasnable effrts will be made t determine an accurate mailing address using internal and external tls and resurces. These effrts will be dcumented n each patient accunt. The detailed plicy is available within the Patient Accunting Plicy, Returned Mail Prcessing. C. Dcumentatin f Cllectin Effrt Patient financial recrds will be maintained by Clumbus Reginal Healthcare System as required by applicable law and in accrdance with hspital plicies. Dcumentatin will supprt billing and cllectin actins and will include all dcumentatin f the hspital's cllectin effrt including the bills, cdes and letter templates, reprts f telephne and persnal cntact, and any ther effrts made. Such dcumentatin is maintained until audit review by a federal and/r state agency f the fiscal year cst reprt in which the bill r accunt is reprted r lnger if required by law r internal plicy. Refer t Dcument Retentin Plicy. D. Ppulatins Exempt frm Cllectin Activities Patients wh are enrlled in a public health insurance prgram including but nt limited t State Medicaid Plans are exempt frm billing r cllectin actin after the initial bill pursuant t state regulatins subject t the fllwing exceptins: (a) Clumbus Reginal Healthcare System m a y seek cllectin actin against any patient enrlled in the abve mentined prgrams fr their required c-payments and deductibles that are set frth by each specific prgram. (b) Clumbus Reginal Healthcare System m a y initiate billing r cllectin activities fr a patient wh alleges that he r she is a participant in a State Prgram that cvers the csts f the services, but fails t prvide prf f such participatin. Upn receipt f satisfactry prf that a patient is a participant in a State Prgram, (including receipt r verificatin f signed applicatin), Clumbus Reginal Healthcare System shall cease their billing r cllectin activities. (c) Prviders m a y seek cllectin actin f r nn-cvered services. 2. Under the Hspital Financial Assistance Prgram, Clumbus Reginal Healthcare System may cease any cllectin r billing actins against a patient wh is unable t pay a bill at any time during the billing prcess. If patient/guarantr is eligible fr Financial Assistance Clumbus Reginal Page 8 f 11

9 Healthcare System w i l l keep any and all dcumentatin that validates the patient met the Hspital Financial Assistance Prgram. 3. Clumbus Reginal Healthcare System and their agents shall nt cntinue cllectin r billing n a patient balances that are part f a bankruptcy prceeding except t secure its rights as a creditr in the apprpriate rder. E. Depsits and Payment Plans Patients r their respnsible parties are expected t pay their full liability fr services rendered within thirty (30) days f receipt f their first bill r in accrdance with a mutually agreed upn installment payment plan Clumbus Reginal Healthcare System will, t the extent permitted by law, request "preadmissin" r "pre-treatment" depsits equal t $350 fr the services t be prvided if the services are: (1) nt cvered by insurance; (2) elective services (i.e., nt Emergency Level Services r Urgent Care Services. Clumbus Reginal Healthcare System ma y require "preadmissin" r "pre-treatment" depsits fr ther services t the extent permitted by law. Clumbus Reginal Healthcare System m a y request a depsit frm patients eligible fr Financial Hardship based n eligibility level. Clumbus Reginal Healthcare System, at a minimum, will ffer the fllwing installment plans but may be, based n the circumstances, permit repayment with a lnger perid. $100 t $300 (3 mnths) $301 t $600 (6 mnths) $601 t $2000 (12 mnths) $2001 t $5000 (24 mnths) Abve $5000 (36 mnths) (With a minimum PPA f $25.00 a mnth) 5. Clumbus Reginal Healthcare System may ffer limited prmpt pay discunts (which are intended t reduce cllectins expenses fr Clumbus Reginal Healthcare System) t patients wh pay utstanding balances within a predefined perid f time. All patients with accunt balances in excess f $0.00 are eligible t receive a prmpt pay discunt f 12% f the balance fr claims paid in full within 30 days f the date f the initial bill. Patients must request the discunt. The discunt cannt be cmbined with Hspital Financial Assistance Prgram. F. Discretinary Settlements Clumbus Reginal Healthcare System m a y c h s e t settle utstanding accunts based upn extenuating circumstances. G. Outside Cllectin Agencies Clumbus Reginal Healthcare System c n t r a c ts with utside cllectin agencies t assist in the cllectin f certain accunts, including patient respnsibility amunts nt reslved after issuance f hspital bills r final ntices. Clumbus Reginal Healthcare System m a y assign, hwever, such debt as bad debt r charity care (therwise deemed as uncllectible) prir t 120 days if Clumbus Reginal Healthcare System is able t determine that the patient was unable t pay under the Hspital Financial Assistance Prgram. Clumbus Reginal Healthcare System has a specific authrizatin r cntract with the utside cllectin agencies and requires such agencies t abide by the Clumbus Reginal Healthcare System credit and cllectin plicies fr thse debts that the agency is pursuing. All utside cllectin agencies hired by Clumbus Reginal Healthcare System wi l l prvide the patient with an pprtunity t file a grievance and will frward t the hspital the results f such patient grievances. Clumbus Reginal Healthcare System r e q u i r e s any utside cllectin agency that they cntract with t fllw Page 9 f 11

10 the regulatins and licensing requirements within the States in which the agency cnducts business.. Additinally cntracted cllectin agencies must abide by the requirements f the Federal Fair Debt Cllectin Practices Act. Bad Debt Pre-Placement Review After the initial three cntacts and after a perid f n less than 120 days frm discharge Self-Pay accunts are pre-listed fr mvement t bad debt. The fllwing actins, if applicable, are then taken: Accunts are remved if any infrmatin has been btained subsequent t being pre-listed that wuld indicate the accunt is cllectible. Primary Bad Debt Placement Primary Bad Debt placement is a prcess that usually ccurs apprximately ne week after the accunts reach the pre-list status. Accunts are submitted t a hspital apprved primary cllectin agency. Accunts remain with the primary cllectin agency fr a perid f at least 270 days The primary cllectin agencies will ntify all patients they cntact fr the purpse f debt cllectin f Clumbus Reginal Healthcare System Financial Assistance plicy. Secndary Bad Debt Placement Secndary Bad Debt placement ccurs after primary placement fr all accunts ver 270 days that have had n payment activity. The secndary agencies will ntify all patients they cntact fr the purpse f debt cllectin f Clumbus Reginal Healthcare System s Financial Assistance plicy. Unpaid accunts stay with secndary agencies fr at least 24 mnths Bad Debt Accunt Recall Clumbus Reginal Healthcare System will recall accunts frm primary and secndary agencies and clear r clean the patients file with bth the agencies and credit bureaus, if applicable, fr the fllwing reasns: Patient files fr bankruptcy Filing f an estate fr the patient Errr by Clumbus Reginal Healthcare System that caused the accunt t imprperly be prelisted (i.e., payment psting errr) Medicare cst Recvery Annually, Clumbus Reginal Healthcare System perfrms a recall f patient accunts based n the qualificatins utlined in the Bad Debt Recall/Recvery Plicy. Legal Cllectin Actins Legal actins may be taken if an accunt ges unpaid after Clumbus Reginal Healthcare System has exhausted ther effrts t cllect n the accunt. Reasnable effrts are made t review every patient s accunt fr financial assistance discunts befre legal actins are taken. The hspital s Financial Cunseling Department is respnsible fr determining if an accunt is eligible fr financial assistance. The Clumbus Reginal Healthcare System CFO has final authrity in determining when legal actins can take place after accunts are determined t be ineligible fr financial assistance. If a patient is fund eligible fr financial assistance after a legal actin has been initiated, legal actin will be reversed and financial assistance discunts will be applied. Legal actins are utlined belw. Fr accunts where patients chse t nt cperate r are nt eligible fr discunts under hspital s cverage and financial assistance prcess, r payment plans ptins, Clumbus Reginal Healthcare System reserves the ptin t refer these accunts fr legal cllectins. Legal actin against individuals may be taken nly when there is sme evidence the patient r respnsible party has incme and/r Page 10 f 11

11 assets t meet their bligatin r did nt cperate with the hspital in demnstrating financial need. Prir t legal cllectin placement, all accunts are reviewed fr financial assistance eligibility. Only accunts fund in-eligible fr financial assistance are subject t legal cllectin placement shuld the patient fail t pay n the accunt. Small Claims Cllectins accunts with balances $300 - $5000 may be referred t lcal Cunty small claims Lawsuits Accunt balances >$5000 may be referred t an attrney fr pursuit f judgments accrding t Nrth Carlina and Suth Carlina laws. Suth Carlina (SC) Tax Set-Off --Wrking thru the S.C. Cunty Cmmissiner Assciatin, Clumbus Reginal Healthcare System files a set-ff claim against any SC tax refund due the patient as allwed in the Suth Carlina statute. <<Insert statute>> Page 11 f 11