Financial Assistance: Defined as assistance available to persons who are 400% or below the Federal Poverty Level.

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1 Financial Assistance CARONDELET HEALTH NETWORK POLICY & PROCEDURE I. POLICY STATEMENT In accordance with Ascension Health Policies 9 and 16, it is the policy of Carondelet Health Network (CHN), as a non-profit, faith-based health network, to provide care to patients who are not able to meet the financial obligation (in part or in total) due to their income restrictions and who are without a payor source for the services rendered. Consistent with its mission, CHN strives to ensure that a patient s financial situation does not prevent them from seeking or receiving care. Financial assistance is not considered to be a substitute for personal responsibility, and patients are expected to cooperate with CHN s procedures for obtaining financial assistance. Individuals with financial capacity to purchase health insurance shall be encouraged to do so as a means of assuring access to health care services. Implementation of this policy shall comply with all federal, state and local laws, rules and regulations and the guidelines of Catholic Health Association that may apply to activities conducted pursuant to this policy. II. DEFINITIONS Financial Assistance: Defined as assistance available to persons who are 400% or below the Federal Poverty Level. Homeless: CHN follows the definition of a homeless individual as defined by the Health Resources and Services Administration (HRSA) in section 330(h)(4)(A) as an individual without permanent housing who may live on the streets; stay in a shelter, mission, single room occupancy facilities, abandoned building or vehicle; or in any other unstable or non-permanent situation. An individual may be considered to be homeless if that person is "doubled up," with a series of friends and/or extended family members for over 90 days. Immediate Family Members: Includes parents, legal guardian, siblings and children. Patient: Shall mean those who receive care at a Carondelet Health Network facility and the person who is financially responsible for the care of the patient. Presumptive Charity Care: Defined as assistance available to persons who meet at least one of the eight criteria outlined below and are without a payor source for the services rendered by CHN. Eight criteria include: Patient dies with no immediate family members; Patient is homeless; Patient has been on Medicaid up to previous 24 months and at discretion of financial counselor; Patient is in Hospice and on Medicaid or is without coverage for this service after financial triage; Patient is within financial eligibility levels for Medicaid, as predicted by capacity to pay model, but refuses to comply with application

2 process or at day 55 is denied; Patient is now on Medicaid or qualifies for Presumptive Charity Care, but has a prior balance; Patient eligible for food stamps; and Other significant barriers are present that preclude patient s ability to provide payment. Undue Hardship: Items that may substantiate hardship include, but are not limited to, loss of home, ability to make a living. III. PURPOSE 1. Streamline the process for CHN to provide presumptive charity care. This policy outlines eight criteria for which patients can qualify for presumptive charity care without proof of documentation that could delay the process. 2. Eligibility for financial assistance. Financial assistance is based on an individualized determination of financial need. Determination of financial assistance shall not take into account age, gender, race, or immigration status, sexual orientation or religious affiliation. 3. Collection practices for patients who qualify for financial assistance. Patients who are cooperating in good faith to resolve their hospital bills will not receive from CHN liens on primary residences, wage garnishments and unpaid bills will not be sent outside to collection agencies. 4. Budgeting and annual plans for financial assistance. Both the Revenue Cycle and Mission Integration departments shall be responsible for overseeing the financial assistance policy and will conduct an annual review of the policy and its implementation. CHN will report financial assistance calculated at cost in the annual Community Benefit Report and shall not include bad debt or contractual discounts. 5. Communication to widely publicize the Financial Assistance Policy throughout the Carondelet Health Network in Emergency and Admitting Departments, lobby areas and other public spaces as well as on the Carondelet website and in patient s financial statements. All information shall be provided in the primary languages spoken by the populations Carondelet serves, English and Spanish. 6. In alignment with our Mission, CHN provides non-discriminatory emergency medical to an individual, regardless of individual s eligibility under the financial assistance criteria outlined below. 7. To reflect CHN s values of Service to the Poor and Reverence for the dignity and diversity of life throughout the financial assistance and collections process, especially for uninsured patients.

3 IV. PROCEDURE Financial Counselor will assist the patient, upon their request, to seek a panel review for possible assistance for those whose incomes are within 400% of the Federal Poverty Level as listed in the key points. The Financial Counselors will independently evaluate the applicant's ability to pay based on a completed charity care application and other documentation, if available. Financial Counselor will comply with the presumptive charity care policy for patients who have demonstrated an inability to pay within a 90-day period from the date of discharge. If the patient meets one or more of the criteria for presumptive charity, the Financial Counselor will put the account in presumptive charity status and document in Meditech. Once the patient has been discharged and all charges have been entered the Financial Counselor will submit an electronic adjustment form for the total amount of financial assistance that the patient is eligible. The Financial Counselors will have the patient complete a financial statement (charity care application) as well as, present other documentation of income and expenses, if available. If upon completion of the charity care application or review of any other documentation, it appears the patient meets one of the seven criteria below, then they patient may be eligible for presumptive charity care: 1. Patient dies with no immediate family members. 2. Patient is homeless as currently resides in a shelter, transitional housing or has stayed with a family member or friend for over 90 days. 3. Patient has been on Medicaid up to previous 24 months and at discretion of financial counselor. 4. Patient is in Hospice and on Medicaid or is without coverage for this service after financial triage. 5. Patient is within financial eligibility levels for Medicaid, as predicted by capacity to pay model, but either refuses to comply with application process or at day 55 is denied. 6. Patient is now on Medicaid or qualifies for Presumptive Charity Care, but has a prior balance. Prior balance can go to Charity Care before 120 days from date of service rendered. 7. Patient eligible for Food Stamps. 8. Other significant barriers are present that preclude patient s ability to provide payment. If the financial counselor is unable to determine level of financial eligibility from initial financial screening, or patient requests financial assistance, the Financial Counselor will provide the patient with a charity care application. This application will be reviewed, along with additional proof of income and expenses, by the Financial Counselor. A level of financial assistance eligibility will be determined and

4 patient will be notified. If the patient qualifies for partial financial assistance, the Financial Counselor will inform the patient of their remaining balance and discuss other payment options to settle the balance. Patients meeting the following criteria are eligible for "free or discounted health services": a) Patients with no insurance who are not eligible for any other government assistance b) Patients with income that fall at or below 400% of the Federal Poverty Level. c) Patients with assets, liquid assets or other available resources may be reviewed for possible charity d) Patient must complete a financial statement e) Patient must provide all the required documentation f) Financial Counselor will refer to Manager. g) The Manager will make a final determination within 14 days of the request. This is in alignment with the adjustment policy and form. Collection Practices: If the patient is not eligible for full financial assistance he or she will be responsible for the remaining account balance. Once the account is final billed, the 45% self pay discount will automatically be adjusted. 30 days from date of discharge-1st Statement 60 days from date of discharge-2nd Statement days from discharge account goes to pre-collect vendor, patient will begin receiving collection calls days from date of discharge account is considered bad debt and is sent to collections. CHN will continue to pursue the payment for up to 5 years after the date of discharge. Communication to widely publicize the Financial Assistance Policy throughout Carondelet Health Network.

5 Key Additional Points: - Charges for emergency or other medically necessary care provided to persons who are eligible for financial assistance under this policy shall not exceed the amounts generally billed to individuals who have insurance coverage for such care. - CHN shall not engage in any type of extraordinary collection efforts before a reasonable effort to determine whether an individual is eligible for financial assistance under this policy has occurred. - In the event of non-payment: Patients will be contacted with the opportunity to re-negotiate payment plan. If unresponsive remaining balance will become due and standard collection practices will resume. - Notices posted and information available in the Emergency and Admitting Departments where they are routinely checked and refreshed by the Financial Counselors. - In addition, lobby areas and other public places where patients, associates and visitors are present will have information available on the Financial Assistance Policy. - Information shall include a contact number to reach a financial counselor and be provided in the primary languages spoken by the populations served by CHN, English and Spanish. - Information about CHN s financial policy is located on the Carondelet website and is included with patient s financial statements.

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