Patient Accounting Services, Patient Financial Assistance Program Author: Executive Sponsor: David P. Johnson, VP Revenue Cycle David P. Johnson, VP Revenue Cycle Date: 10/4/2015 Policy Type Entity Governance Policy Entity Policy Entity Departmental Policy Policy Scope System Governance Policy System Policy System Departmental Policy Home Office Policy Summa Health (Corporate) Summa Health System (Hospitals) Summa Health Network New Health Collaborative Summa Physicians, Inc SMSO Summacare Department: Patient Account Services Page 1 of 9
Patient Account Services, Healthcare Financial Assistance Program Policy Statement: Summa Health System is committed to providing financial assistance responsive to the needs of the community, regardless of race, age, gender, color, ethnic background, national origin, citizenship, primary language, religion, disability, handicap, education, employment or student status, disposition, relationship, insurance coverage, community standing, or any other discriminatory differentiating factor. Healthcare Financial Assistance ( HFA ) is a program that is fully funded by Summa Health System. It covers patients without health insurance and those with only partial insurance coverage (i.e. the uninsured and underinsured) who meet the income and other eligibility criteria described herein. Related Policies: Summa Health System offers other options for uninsured or underinsured patients who do not qualify for financial assistance under this HFA policy. For further information, please see the following Summa Health System policy: Summa Health System Ohio Hospital Care Assurance Program Policy Commitment to Provide Emergency Medical Care: Summa Health System provides care, without discrimination, for emergency medical conditions to all individuals regardless of whether they can pay or are eligible for assistance under this HFA policy. Summa Health System will not engage in actions that discourage individuals from seeking emergency medical care, such as by demanding that emergency department patients pay before receiving treatment for emergency medical conditions or by permitting debt collection activities that interfere with the provision of emergency medical care. Emergency medical services, including emergency transfers, pursuant to the Federal Emergency Medical Treatment and Labor Act are provided to all Summa Health System patients in a non-discriminatory manner. Services Eligible for HFA: This HFA policy applies to all emergency and other medically necessary care provided by the Summa Health System, as well as certain other providers delivering emergency or other medically necessary care in Summa Health System s facilities. Attached is a list of providers, other than the Summa Health System, delivering such care in Summa Health System facilities, that specifies which providers are covered by this HFA policy and which are not covered (see Attachment A). The following services are not covered under this HFA policy: Items deemed not medically necessary. Cosmetic surgery (identify by diagnosis & procedure done, etc.) Bariatric charges. Page 2 of 9
HFA Eligibility Criteria: Income To apply for HFA, a patient or family member must complete an application (see Attachment B) including gross income for a minimum of 3 months (up to 12 months) prior to the date of application or date of service. Proof of income is requested from all patients requesting financial assistance consideration. Third party income scoring may be used to verify income in situations where income verification is unable to be obtained through other methods. Assets There are situations where individuals may not have reported income but have significant assets available to pay for healthcare services. In these situations, Summa Health System may evaluate these assets as cash available to meet essential living expenses, which includes healthcare expenses. Health Savings Accounts Summa Health System requires proof that Health Savings Account and/or Medical Savings Account funds have been depleted prior to providing healthcare financial assistance. Federal Poverty Guidelines HFA eligibility is based upon expanded income levels of up to 400% of FPG and is prorated on a sliding scale. (see Attachment C). Approval is based upon the number of family members and family income. If a dependent is disabled and over the age of eighteen, he/she will be included in family size. Health Insurance Marketplace (Exchange) Participation If a patient has elected not to enter the marketplace/exchange, financial assistance may not be extended until they do so. Exceptions to this policy include patients discharged to a SNF, patients who are deceased with no estate, and patients who have documented homelessness. Healthcare financial assistance may be offered once the patient meets the requirement for insurance. Geographic Area Patients who live in the community served by a Summa Health System (Summit, Portage, and Medina counties) will be offered healthcare financial assistance. For those patients living outside of the geographic area, extenuating circumstances must be documented and approved by the PFS Manager. Deductibles For patients who have self-pay balances after insurance, balances attributed to the patients deductible will require payment based on a sliding scale given their current household income (see Attachment C). Upon receipt of the signed application, the information will be reviewed, income verified, and an eligibility determination will be made. Page 3 of 9
Presumptive Eligibility When a patient is personally unable, does not have a family member or executor or does not have an assigned power of attorney to complete patient s application, the patient may be presumed to be eligible for financial assistance. Patients discharged to a SNF, patients who are deceased with no estate, and patients who have documented homelessness, may fall into this application exception and qualify as presumptive eligibility. Patients determined to have presumptive financial assistance eligibility have no patient liability. Summa Health System shall utilize available resources (e.g. technology solutions, service organizations, etc.) to obtain such information as credit score in order to assist in determining whether a patient is presumed eligible for financial assistance. Cooperation Patients/guarantors shall cooperate in supplying all third party information including Motor Vehicle or other accident information, requests for Coordination of Benefits, pre-existing information, or other information necessary to adjudicate claims, etc. While the application is being processed, Summa Health System will request that patients who may be Medicaid-eligible apply for Medicaid. In order to receive healthcare financial assistance, the patient must apply for Medicaid and be denied for any reason other than the following: o Did not apply; o Did not follow through with the application process; o Did not provide requested verifications. Accuracy of Application Financial assistance may be denied under this HFA policy if there is reasonable suspicion of the accuracy of an application. If the patient/guarantor supplies the needed documentation and/or information requested to clarify the application, the financial assistance request may be reconsidered. Reconsideration will be reviewed and handled on a case-by-case basis. Application Process for HFA: Application forms (see Attachment B) are made available in Pre-Registration, Admission / Registration, and several alternative registration sites to facilitate early identification and initiation of the application process. Application forms may also be obtained by contacting Summa Health System as indicated on Page 6. Summa Health System may accept verbal clarifications of income, family size or any information that may be unclear on an application. Inpatients will be required to complete an application for each admission unless the patient is readmitted within 45 days of discharge for the same underlying condition. Approved outpatient applications are effective for 90 days from initial date of service. An inpatient application can also be used to cover outpatient services for the patient in the 90-day period immediately following the first day of the inpatient admission. Page 4 of 9
Applications will be valid retrospectively for a period of 3 years prior to the date of application regardless of inpatient or outpatient status. Financial Assistance for Catastrophic Situations: Summa Health System defines Catastrophic Situations as incurred medical expenses that result in patient responsible debts of greater than 25% of the gross annual family income. Financial assistance for a catastrophic situation is available in accordance with Summa Health System s Financial Aid Catastrophic Policy. Basis for Calculating Amounts Charged to Patients: Following a determination of eligibility under this policy, a patient eligible for financial assistance will not be charged more for emergency or other medically necessary care than the amount generally billed (AGB). At least annually, Summa Health System calculates an AGB percentage based on the Look-back Method (as defined by Treasury Regulations under section 501(r) of the Internal Revenue Code of 1986, as amended). Members of the public may obtain the current AGB percentage for any Summa Health System (and a description of the calculation) in writing and free of charge by contacting Summa Health System as indicated on Page 6. Summa Health System does not bill or expect payment of gross charges from individuals who qualify for financial assistance under this policy. Actions Taken in the Event of Nonpayment: The actions that Summa Health System may take in the event of nonpayment are described in a separate Billing and Collections Policy. Members of the public may obtain a free copy of this separate policy from the Summa Health System PFS by contacting Summa Health System as indicated on Page 6. Measures to Widely Publicize the HFA Policy: Summa Health System makes this HFA policy, application form, and plain language summary of the policy widely available on its website, and implements additional measures to widely publicize the policy in communities served. o o o o Website http://www.summahealth.org/patientvisitor/insuranceandbilling/charity-program-policy Signage in all registration areas. Statement of Financial Assistance Program on each patient statement Financial Assistance Programs referenced in each personal contact phone call. Summa Health System also accommodates significant presenting populations (greater than1000) within our community that have limited English proficiency by translating this HFA policy, all related billing and collection policies, the application form, and plain language summary of the policy into the primary language(s) spoken by such populations. Page 5 of 9
Financial Counselors Financial counselors are available to answer your questions about payment arrangements, insurance coverage, Medicare and other financial inquiries. For more information about financial counseling, please call: Summa Akron City Hospital (330) 375-6685 Summa Barberton Hospital (330) 615-3236 Patient Account Services Contact Summa Patient Account Services at (234) 312-5700 or (800) 543-7750 (in Ohio). Representatives are available Monday through Friday from 8:00 am to 4:30 pm Notice to Ohio Residents Ohio Hospital Care Assurance Program (HCAP): Summa Health System provides, without charge to the individual, basic, medically necessary hospital-level services to individuals who are residents of Ohio, are not Medicaid recipients, and whose income is at or below the federal poverty line. Covered services are inpatient and outpatient services covered under the Ohio Medicaid Program, with the exception of transplantation services and services associated with transplantation. Recipients of Disability Financial Assistance qualify for assistance. Ohio residency is established by a person who is living in Ohio voluntarily and who is not receiving public assistance in another state. Requests for financial assistance for Ohio residents are processed for HCAP first, and then are otherwise subject to the provisions of this HFA policy. Attachments: A. Provider Listing B. Financial Application C. Federal Poverty Guidelines Page 6 of 9
Attachment A : Services Eligible for HFA: In addition to the services of the hospitals of Summa Health System, Physicians that provide care within the Summa Health System are covered by this Summa Health System HFA policy include; Team Health Akron Radiology US Acute Care Solutions (USACS) Summa Emergency Associates (SEA) Summit Pathology IMS group Summa Physicians Inc. (providing Anesthesia services) (providing Radiology services) (providing Emergency room services as of 1/1/2017) (providing Emergency room services prior to 1/12017) (providing Pathology services) (Hospitalist group providing inpatient daily care services) (Primary Care and Specialty Care Physicians employed by Summa Health) The actual discount percentages will vary for each of the physician groups as each will have a unique AGB. Physicians that are Not covered under the Summa Health System Financial Assistance Program. All other physicians not listed above Page 7 of 9
Attachment B : Page 8 of 9
Attachment C : Federal Poverty Index is updated by the Federal Government annually. Effective for dates of service beginning 01/01/2016 Income & Family Size Compared to 2016 Federal Guidelines for Poverty Family Size Income level up to : Federal Poverty Index 200% 250% 300% 350% 400% 1 $11,880 $23,760 $29,700 $35,640 $41,580 $47,520 2 $16,020 $32,040 $40,050 $48,060 $56,070 $64,080 3 $20,160 $40,320 $50,400 $60,480 $70,560 $80,640 4 $24,300 $48,600 $60,750 $72,900 $85,050 $97,200 5 $28,440 $56,880 $71,100 $85,320 $99,540 $113,760 6 $32,580 $65,160 $81,450 $97,740 $114,030 $130,320 7 $36,730 $73,460 $91,825 $110,190 $128,555 $146,920 8 $40,890 $81,780 $102,225 $122,670 $143,115 $163,560 Discount level 100% 100% 100% 90% 85% 78% Page 9 of 9