Current Status: Active PolicyStat ID: Collection Policy

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1 Current Status: Active PolicyStat ID: Effective: 08/2005 Approved: 12/2015 Last Revised: 12/2015 Expires: 12/2018 Author: Manager of Revenue Cycle Policy Area: Patient Financial Services References: PURPOSE: Collection Policy This policy, together with the Financial Assistance Program/Community Care (known throughout this policy as "Community Care/FAP"), EMTALA, and Elective Procedure policies, is intended to meet the requirements of all applicable Federal, State and local laws, including, without limitation, section 501(r) of the Internal Revenue Code. This policy establishes the actions that may be taken in the event of non-payment for medical care provided by BAMC, including collection actions and reporting to collection agencies. Bay Area Medical Center and its affiliates (collectively, BAMC) are committed to collecting balances in a way that treats all patients equally with respect, and to ensure that the appropriate billing and collection procedures are uniformly followed. POLICY: BAMC's payment plan options include Community Care/FAP, Hardship status, and Medical Line of Credit for Uninsured/Self-Pay after Insurance (the "Payment Options"). Each Payment Option is exclusive of the other Payment Options. BAMC is committed to assisting our patients in selecting the best option to meet their individual needs. Follow-up on self-pay accounts will be done professionally, timely and consistently. BAMC will identify additional accounts that may qualify for a Payment Option. BAMC will make reasonable efforts to determine whether an individual is eligible for Community Care prior to engaging in any ECAs. This policy does not create any rights for any individuals beyond those rights contained in applicable laws. DEFINITIONS: Extended Application Period: The period of time starting the day after the Initial Application Period and extending for 120 days thereafter. Extraordinary Collection Actions (ECAs): Extraordinary Collection Actions include any action against an individual relating to obtaining payment of a balance that requires a legal or judicial process, or involves selling of a balance to another party, or reporting adverse information about the individual to consumer credit reporting agencies or credit bureaus. ECAs include: (i) Selling an individual's debt to another party (other than a sale of debt that complies with Section Retrieved 12/14/2015. Official copy at Copyright 2015 Bay Area Medical Center Page 1 of 5

2 1.501(r)-6(b)(2) of the Treasury Regulations); (ii) reporting adverse information about the individual to consumer credit reporting agencies or credit bureaus; (iii) deferring or denying, or requiring a payment before providing, medically necessary care because of an individual's nonpayment of one or more bills for previously provided care covered under BAMC's Community Care/FAP Program; and (iv) actions that require a legal or judicial process, including but not limited to (A) placing a lien on an individual's property (other than a lien permitted under this policy); (B) foreclosing on an individual's real property; (C) attaching or seizing an individual's bank account or any other personal property; (D) commencing a civil action against an individual; (E) causing an individual's arrest; (F) causing an individual to be subject to a writ of body attachment; and (G) garnishing an individual's wages. ECAs do not include: (1) any lien that BAMC is entitled to assert under state law on the proceeds of a judgment, settlement, or compromise owed to an individual (or his or her representative) as a result of personal injuries for which the hospital facility provided care; (2) the filing of a claim in any bankruptcy proceeding; or (3) the sale of debt that complies with Section 1.501(r)-6(b)(2) of the Treasury Regulations. Individual: Under this Policy, an individual includes the individual who received medical care from BAMC and any other individual who has accepted or is required to accept responsibility for the individual's bill for the medical care. Initial Application Period: The period of time starting the day BAMC sends the individual his or her first post-discharge billing statement and extending for 120 days thereafter. Third-Party Coverage: Payment for the individual's medical services by (1) A third-party insurance plan, (2) a federal, state or local governmental health care program (including without limitation, Medicare, Medical Assistance, SCHIP and Tricare), (3) Worker's Compensation, Medical Savings account or other coverage for any part of the bill, including claims against liable third-parties. Total Application Period: The total time period covered by the Initial Application Period and the Extended Application Period. Hardship Status: Individuals who are not eligible for BAMC's Community Care/FAP program may qualify for Hardship Status. Hardship Status is granted based on an income level from % of the Federal Poverty Guidelines. Balance Timeline for Payment in full BAMC Payment Arrangement Guidelines: $1 - $750 3 months $751 - $2,500 6 months $2,501-$5,000 9 months >$5, months Retrieved 12/14/2015. Official copy at Copyright 2015 Bay Area Medical Center Page 2 of 5

3 PROCEDURE: Billing Procedures BAMC may request payment for any known patient responsibility for medical care prior to or at the time care is provided (other than Emergency Care). With respect to Emergency Care, BAMC may request payment for any known patient responsibility after the care is provided. If a patient has not paid BAMC at the time medical care is provided, BAMC will bill the individual for the amount due after receipt of any third-party coverage payments. BAMC will bill individuals for any outstanding balances using its normal billing process, which includes a minimum of 4 (four) statements over a span of at least 120 days. BAMC shall include a plain language summary of the Community Care program with each of the four statements. If an individual qualifies for Community Care/FAP, a discount will be given in accordance with the Community Care/FAP policy. Individuals may apply for the Community Care/FAP program at any time during the Total Application Period. After an individual's submission of the Community Care/FAP application during the Total Application Period, BAMC will determine whether the individual is eligible for Community Care/ FAP. Upon receipt of the application, BAMC will suspend any ECAs to obtain payment by not initiating or taking further action on any previously-initiated ECAs until BAMC has determined whether the individual is eligible for Community Care/FAP or the individual has failed to respond to requests for additional information and/or documentation within a reasonable period of time given to respond to such requests. BAMC will also make a determination as to whether the individual is eligible for Community Care/FAP and notify the individual in writing of this eligibility determination and the basis for the determination. BAMC will refund to the individual any amount he or she paid for the care that exceeds the amount he or she is determined to be personally responsible for paying as a Community Care/ FAP-eligible individual. BAMC will also take all reasonable available measures to reverse any ECAs with the exception of a sale of debt. If an individual submits an incomplete Community Care/FAP application during the Total Application Period, BAMC will notify the individual about how to complete the Community Care/ FAP application and give the individual a reasonable opportunity to complete the application. The notification to the individual will be written and describe the additional information and/or documentation required under the Community Care/FAP program and application. BAMC will also suspend any ECAs to obtain payment by not initiating or taking further action on any previously-initiated ECAs until BAMC has determined whether the individual is eligible for Community Care/FAP or the individual has failed to respond to requests for additional information and/or documentation within a reasonable period of time given to respond to such requests. In determining whether the individual is eligible for Community Care/FAP, BAMC will not base its determination on information BAMC has reason to believe is unreliable or incorrect or on information obtained from the individual under duress or through the use of coercive practice. If the individual is not eligible for Community Care/FAP, then BAMC will determine whether the individual is eligible for hardship status or offer a medical line of credit. BAMC may also engage in ECAs at this time. Retrieved 12/14/2015. Official copy at Copyright 2015 Bay Area Medical Center Page 3 of 5

4 Collection Procedures During the Initial Application Period, BAMC shall not refer the account to a collection agency or engage in ECAs. If payment in full or an acceptable payment arrangement is not agreed upon during the Initial Application Period, BAMC may refer the bad debt account to a collection agency for additional collection efforts in accordance with this policy or otherwise engage in ECAs. However, BAMC will do the following at least thirty days prior to initiating any ECAs: (1) provide the individual with a written notice that indicates financial assistance is available for eligible individuals, that identifies the ECA(s) that BAMC intends to initiate to obtain payment for the care, and that states a deadline after which such ECA(s) may be initiated that is no earlier than 30 days after the date that the written notice is provided; (2) provide the individual with a plain language summary of the Community Care/FAP policy and program with the written notice; and (3) make a reasonable effort to orally notify the individual about BAMC's Community Care/FAP and about how the individual may obtain assistance with the Community Care/FAP application process. Subject to the requirements of this Policy, contracted collection agencies may use the following collection methods in an attempt to collect bad debt accounts: Telephoning, or mailing the guarantor Skip tracing Reporting bad debt accounts to credit reporting agencies Sale of an individual's debt to another party Initiation of civil litigation actions in accordance with procedures contained in this policy BAMC may authorize its contracted collection agencies to initiate civil litigation actions to collect bad debt accounts, including, but not limited to: pursuing money judgment, lien attachments to assets, and garnishment of wages. Uninsured/Self-Pay after Insurance and Hardship Status Uninsured individuals will receive a 45% discount on their total charges. The discount will not apply to elective cosmetic procedures. Uninsured individuals are defined as those who have no form of insurance coverage, cannot be retroactively qualified for any type of coverage, and do not qualify for Community Care/FAP. The expectation is that all uninsured and self-pay balances after insurance are to be paid within 30 days from receipt of first billing statement. If an individual's balance is not resolved within 30 days, a minimum payment plan must be established within BAMC's Payment Arrangement Guidelines. If an individual requires more time to pay than allowed under the acceptable Payment Arrangement Guidelines, BAMC will offer a payment plan with interest at the prime interest rate under a medical line of credit. Individuals who do not qualify for Community Care/FAP may qualify for a Hardship Status. Hardship Status is based on an individual's ability to pay and allows minimum monthly payments without interest charges for a period not to exceed five years. If the individual does not qualify for Community Care/FAP, has not made acceptable payments under BAMC's Payment Arrangement guidelines, or refuses to set up a payment arrangement under these terms, the balance will be referred to a collection agency. Retrieved 12/14/2015. Official copy at Copyright 2015 Bay Area Medical Center Page 4 of 5

5 I. RESPONSIBILITY: Questions regarding this policy should be directed to the Financial Counselor at (715) or toll-free at 1(888) ext Attachments: No Attachments Approver Date Finance Director 12/2009 Finance Director 03/2010 Manager of Revenue Cycle 06/2013 Clinic Business Services Mgr 06/2013 Manager of Revenue Cycle 06/2013 Clinic Business Services Mgr 06/2013 Manager of Revenue Cycle 12/2015 Clinic Business Svcs Manager 12/2015 Retrieved 12/14/2015. Official copy at Copyright 2015 Bay Area Medical Center Page 5 of 5

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