INOVA FINANCIAL ASSISTANCE POLICY STATEMENT

Transcription

1 INOVA FINANCIAL ASSISTANCE POLICY STATEMENT Revised Date: 01/01/15 Replaces: 10/01/13 I. POLICY Inva s missin is t prvide medically necessary health care t persns regardless f their ability t pay. Inva interprets its charitable missin f cmmunity services bradly, and will pursue the bjective that persns wh require medically necessary health care services receive them regardless f their ability t pay. Inva has established this plicy fr the prvisin f Financial Assistance in rder t manage its resurces respnsibly and t allw Inva s entities t prvide the apprpriate level f assistance t the greatest number f persns in need. This Financial Assistance plicy applies t medically necessary services prvided by each f Inva s entities, and shall cmply with any binding agreements with lcal gvernments and all state and federal laws and regulatins. Inva als prvides, withut discriminatin, care fr Emergency Medical Cnditins t individuals regardless f their eligibility fr Financial Assistance. As further described belw, this Financial Assistance plicy: 1. Includes eligibility criteria fr Financial Assistance. 2. Describes the basis fr calculating amunts charged t patients eligible fr Financial Assistance under this plicy. 3. Describes the methd by which patients may apply fr Financial Assistance. 4. Describes hw Inva will widely publicize the plicy within the cmmunity served by each entity. 5. Limits the amunts that Inva s entities will charge fr emergency r ther medically necessary care prvided t individuals eligible fr Financial Assistance t n mre than the lwest amunts generally billed (received by) Inva fr cmmercially insured patients. Inva s Financial Assistance plicy prvides a 100 percent discunt (full cverage) fr thse with incmes at r belw 200% f the current Federal Pverty Levels (FPL) and sliding scale cverage fr thse with incmes abve 200% and 300% f the FPL. Catastrphic (high-dllar) Financial Assistance als is available fr patients wh live in Inva s primary service areas and with limited means (abve 300% and at r less than 500% f FPL) wh, due t the nature and extent f services prvided have significant care-related financial bligatins after cnsidering all ptential payment surces. Financial Assistance applicatins are valid fr a six-mnth perid. Accunts with any balances after Financial Assistance discunts are referred t Inva MediCredit, an Inva prgram which ffers reasnable, zer interest payment plans. The Inva Financial Assistance prgram is nt an insurance plicy. Inva encurages uninsured and underinsured patients t apply fr public prgrams fr which they may be eligible; hwever, failure t apply fr public health insurance r medical assistance prgrams will nt disqualify patients frm applying fr Financial Assistance fr the current date f service. Patients returning fr additinal services will again be encuraged t apply fr public health insurance r medical assistance prgrams and, if their Financial Assistance applicatins are nt valid, will als be encuraged t reapply fr Financial Assistance. In terms f scpe, Inva will prvide Financial Assistance fr eligible patients accrding t this plicy, as fllws: 1

2 1. Financial assistance is available t lw-incme patients wh meet Inva s guidelines and wh have partial cverage (e.g., n fault care insurance, secndary Medicaid r Medicare) but wh are still unable t pay the remainder f their bills. 2. Financial Assistance is available t lw-incme patients that have applied fr and were subsequently denied fr Medicaid due t excess incme r resurces, and/r d nt meet the emergency/disability requirements fr the prgram. 3. Financial Assistance is available t lw-incme patients wh may qualify fr a public assistance prgram and meet Inva s guidelines, but wh d nt cmplete the applicatin prcess despite Inva s best effrts. 4. Financial Assistance des nt include cntractual allwances (the difference between the hspital/physician ttal charge and the negtiated insurance rate) with Medicare, Medicaid, r health plans. This des nt include prmpt-pay discunts and self-pay discunts prvided t patients regardless f means. 5. Bth nn-citizens and permanent residents are eligible t receive Financial Assistance. Hwever, patients in the United States n a student visa r a turist visa will nly be cnsidered fr emergency care admissins. Further, there is a residency requirement fr catastrphic (high dllar) Financial Assistance. 6. Patients are expected t cperate with and prvide apprpriate and timely infrmatin t Inva t btain Financial Assistance r ther frms f payment, and are als expected t cntribute t the cst f their care based n their ability t pay. Individuals with the financial capacity t purchase health insurance shall be encuraged t d s, as a means f assuring access t health care services, fr their verall persnal health, and fr the prtectin f their assets. II. DEFINITIONS Fr the purpse f this plicy, the terms belw are defined as fllws: A. Eligible Services: Services prvided by Inva s entities which are eligible fr Financial Assistance include: (1) emergency medical services prvided in an emergency rm setting; (2) nn-elective services prvided in respnse t life-threatening circumstances in a nn-emergency rm setting; and (3) ther Medically Necessary services. B. Emergency Medical Cnditins: Defined within the meaning f sectin 1867 f the Scial Security Act (42 U.S.C. 1395dd). C. Family: Using the Census Bureau definitin, a grup f tw r mre peple wh reside tgether and wh are related by birth, marriage, r adptin. Accrding t Internal Revenue Service rules, if the patient claims smene as a dependent n their incme tax return, they may be cnsidered a dependent fr purpses f the prvisin f financial assistance. D. Family Incme: Family Incme is determined as fllws: Includes earnings, unemplyment cmpensatin, wrkers cmpensatin, Scial Security, Supplemental Security Incme, public assistance, veterans payments, survivr benefits, pensin r retirement incme, interest, dividends, rents, ryalties, incme frm estates, trusts, educatinal assistance, alimny, child supprt, assistance frm utside the husehld, and ther miscellaneus surces; Determined n a befre-tax basis; Excludes capital gains r lsses; and If a persn lives with a family, includes the incme f all family members (nn-relatives, such as husemates, d nt cunt). 2

3 E. Grss Charges: The ttal charges at the rganizatin s full established rates fr the prvisin f patient care services befre deductins frm revenue are applied. F. Incme Dcumentatin: Acceptable family incme dcumentatin shall include ne (1) f the fllwing: a cpy f the mst recent tax return; cpies f the 2 mst recent pay stubs written incme verificatin frm an emplyer if paid in cash; r ne ther reasnable frm f third party incme verificatin deemed acceptable t Inva. G. Medically Necessary: As defined by Medicare (services r items reasnable and necessary fr the diagnsis r treatment f illness r injury). H. Uninsured: The patient has n level f insurance r third party assistance t assist with meeting his/her payment bligatins. I. Underinsured: The patient has sme level f insurance r third-party assistance but still has ut-fpcket expenses that exceed his/her financial abilities. J. AGB: Amunts Generally Billed is determined by ne f tw methds used by hspitals, the lkback methd r the Medicare Prspective methd. Inva utilized the lk-back methd t establish a 50% discunt rate fr patients withut insurance wh may be eligible fr financial assistance. III. PROCEDURES A. Eligibility fr financial assistance. Financial Assistance will be prvided fr Eligible Services fr thse patients wh are uninsured, underinsured, ineligible fr any gvernment health care benefits prgram, r wh are therwise unable t pay fr their care, based upn a determinatin f financial need in accrdance with this plicy. The granting f Financial Assistance shall be based n an individualized determinatin f financial need, and shall nt take int accunt age, gender, race, natinal rigin, scial r immigrant status, sexual rientatin r religius affiliatin. B. Financial Assistance Eligibility Determinatins. 1. Eligibility fr Financial Assistance will be determined in accrdance with prcedures that invlve an individual assessment f financial need. These prcedures include: a. An applicatin prcess, in which the patient r the patient s guarantr supply persnal, financial and ther infrmatin and dcumentatin relevant t making a determinatin f financial need; b. The use f external publically available data surces that prvide infrmatin n a patient s r a patient s guarantr s ability t pay (such as credit scring); c. Individuals wh are deemed eligible by the Virginia Uninsured Patient Discunt Act. The Federal Pverty Guidelines calculatins will als be updated annually in cnjunctin with the published updates by the United States Department f Health and Human Services; d. An accunting f the patient s available assets, and ther financial resurces available t the patient. 2. It is preferred but nt required that a request fr Financial Assistance and a determinatin f financial need ccur prir t Eligible Services. Hwever, the determinatin may be dne at any pint in the registratin, patient care, r revenue cycle prcess. The need fr Financial 3

4 Assistance shall be re-evaluated at each subsequent time f Eligible Services if the Financial Assistance Applicatin n file is invalid. 3. Inva s values f human dignity and stewardship shall be reflected in the applicatin prcess, financial need determinatin and granting f Financial Assistance. Requests fr Financial Assistance shall be prcessed prmptly and Inva shall make reasnable effrts t ntify the patient r applicant in writing within 30 days f receipt f a cmpleted applicatin. C. Presumptive Financial Assistance Eligibility. There are instances when a patient may appear eligible fr Financial Assistance, but the patient has nt prvided dcumentatin needed t establish such eligibility. In certain cases, infrmatin prvided by the patient and/r available thrugh ther surces wuld prvide sufficient evidence t justify prviding the patient with Financial Assistance. In these circumstances, Inva may use utside agencies in determining estimated incme amunts fr the basis f determining Financial Assistance care eligibility and ptential discunt amunts. Once determined, due t the inherent nature f the presumptive circumstances, discunts up t 100% f the accunt balance may be apprpriate. Presumptive eligibility is determined if dcumentatin is prvided that the patient is eligible fr the fllwing prgrams r has the fllwing individual life circumstances: 1. State-funded prescriptin prgrams; 2. Hmeless r received care frm a hmeless clinic, free clinic, Cmmunity Health Care Netwrk (CHCN), Healthy Cmmunity Access Prgram (HCAP), Streamline Eligibility System (SES) r federally qualified health centers. 3. Participatin in Wmen, Infants and Children prgrams (WIC); 4. Fd stamp eligibility; 5. Subsidized schl lunch prgram eligibility; 6. Eligibility fr ther state r lcal assistance prgrams that are unfunded (e.g., Medicaid spenddwn); 7. Lw incme/subsidized husing is prvided as a valid address; and 8. Patient is deceased with n knwn estate. D. Eligibility Criteria and Amunts Charged t Patients. Eligible Services under this plicy will be prvided t the patient, in accrdance with financial need, as determined in reference t Federal Pverty Levels (FPL) in effect at the time f the determinatin. Once a patient has been determined by an Inva entity t be eligible fr Financial Assistance, that patient shall nt receive any future bills based n undiscunted grss charges. The basis fr the amunts that each Inva entity will bill patients qualifying fr Financial Assistance is as fllws: 1. N Financial Aid Plicy (FAP)-eligible individual will be charged mre than AGB fr emergency r ther medically necessary care; 2. Patients wh qualify fr the sliding scale payments as defined in the Financial Aid Plicy (FAP) are eligible fr a 50% discunt (the AGB discunt) which will be applied subsequent t any ther applicable FAP related reductins: 3. Patients whse family incme is equal t r belw 200% f the FPL r wh are fund eligible fr Financial Assistance n a presumptive basis are eligible t receive free care; 4. Patients whse family incme is abve 200% but n mre than 300% f the FPL are eligible t receive services that reflect the AGB discunt and an additinal sliding scale discunt. 5. Patients with limited means (defined as family incme equal t r belw 500% f the FPL), wh due t the nature and extent f Eligible Services prvided have significant care related 4

5 financial bligatins are eligible t receive additinal Financial Assistance if their accunt balances after cnsidering all ptential payment surces and applicable Financial Assistance and AGB discunts are abve 50% f their Family Incme. In such circumstances, patient bills will be limited t the lesser f 50% f Family Incme r the amunts generally billed t (received by an Inva entity fr) cmmercially insured patients fr such care. Patients must meet the fllwing criteria t qualify fr this additinal assistance: a. Must be a dcumented resident f the Inva primary service area b. Must nt be eligible fr any insurance, gvernmental, r ther surces f payment c. Must have annual Family Incme greater than 200% and at r less than 500% f the applicable FPL based n family size d. Must have less than $75,000 available assets ( e.g. savings, checking, r security accunts) e. Ttal patient grss charges n accunt(s) must exceed $25, 000 (this may by adjusted frm time t time fr inflatin) E. Cmmunicatin f the Financial Assistance Prgram t Patients and Within the Cmmunity. Ntificatin abut Financial Assistance available frm Inva s entities, which shall include a cntact number, shall be disseminated by Inva by varius means, which include, but are nt limited t, the publicatin f ntices in patient bills and by psting ntices in emergency rms, in the Cnditins f Admissin frm, at urgent care centers, admitting and registratin departments, Inva ffices, and Patient Financial Services ffices lcated n facility campuses, and at ther public places as Inva may elect. Inva will als publish and widely publicize a summary f this plicy n Inva s websites (with a link t this full plicy), in brchures available in patient access sites and at ther places within the cmmunity served by Inva. Such ntices and summary infrmatin and this full plicy shall be prvided in the five mst frequent languages spken by the ppulatin serviced by Inva. Inva Ambulatry Care Facilities include: Ambulatry Surgery Centers (Cuntryside, Francnia-Springfield, Nrthern Virginia, Ludun Ambulatry Surgery Center, and Wdburn) IECC s (Inva Emergency Care Centers Fairfax, Healthplex, Lrtn, and Restn) IPTC s (Inva Physical Therapy Centers 13 lcatins) UCC s (Urgent Care Centers Centreville, Dulles Suth and Vienna, Ballstn, and Wdbridge) Inva Diabetes Centers (Alexandria, Fair Oaks, Ludun, Munt Vernn, and Prsperity) Healthsurce, Juniper Prgram, Kellar Center, Life with Cancer, and Ptmac Radiatin Onclgy F. Relatinship t Cllectin Plices: Each Inva entity shall cmply with the Inva guidelines fr cllectin agencies and attrneys and Federal and State Laws and Regulatin gverning healthcare billing and cllectins. Inva s cllectins plicies take int accunt the extent t which the patient qualifies fr Financial Assistance and a patient s gd faith effrt t cmply with his r her payment agreements. Fr patients wh qualify fr Financial Assistance and wh are cperating in gd faith t pay their discunted bills, Inva may ffer extended payment plans, and will nt send unpaid bills t utside cllectin agencies. N Inva entity will impse extrardinary cllectin actins such as: decisins t deny r defer Financial Assistance based n a patient s utstanding accunts receivable and a patient s payment histry, wage r bank garnishments, liens n primary residences r estates, r ther legal actins against any patient, withut first making reasnable effrts t determine whether that patient is eligible fr assistance under this Financial Assistance plicy. Reasnable effrts shall include: 1. Multiple invices t the patient, frm bth Inva and frm Inva s internal and external cllectin agencies, t infrm the patient f the amunt wed; 5

6 2. Attempts t cntact nn-respnsive patients via telephne r ther means f cmmunicatin t infrm the patient f the amunt wed and t discuss payment ptins, including eligibility fr Financial Assistance; 3. Validatin that the patient wes the unpaid amunt and that all surces f third-party payment have been identified and billed by Inva; 4. Dcumentatin that Inva has r has attempted t ffer the patient the pprtunity t apply fr Financial Assistance care pursuant t this plicy and that the patient has nt cmplied with the Inva s applicatin requirements; 5. Dcumentatin that the patient des nt qualify fr Financial Assistance n a presumptive basis; 6. Dcumentatin that the patient has been ffered a payment plan, but has nt hnred the terms f that plan. G. Regulatry Requirements. In implementing this Plicy, the Inva entities shall cmply with all ther federal, state, and lcal laws, rules, binding agreements, and regulatins that may apply t activities cnducted pursuant t this Plicy. H. Means f Applying fr Financial Assistance. Patient may apply fr Financial Assistance by cmpleting an applicatin frm. The frm is ffered t patients at the time they receive care at an Inva entity. The frm is available fr dwnlad at and may als be requested by calling Instructins fr cmpletin and submissin f the applicatin frm are n the frm itself. Further, referral f patients fr Financial Assistance may be made by any Inva staff r medical staff member, including physicians, nurses, financial cunselrs, scial wrkers, case managers, chaplains, and religius spnsrs. A request fr Financial Assistance may be made by the patient r a family member, clse friend, r assciate f the patient, subject t applicable privacy laws. I. ELIBILITY CRITERIA FOR INOVA FINANCIAL ASSISTANCE PROGRAM The tables belw are based upn Federal Pverty Levels that are in effect fr the 2015 calendar year, and shall be updated annually t reflect the then-current FPL and t assure that amunts billed t any patients qualifying fr Financial Assistance d nt exceed the amunts generally billed t (received by Inva fr) cmmercially insured patients fr such care. The table belw is based upn 2015 Federal Pverty Guidelines. Family Size 2015 Federal Pverty Guidelines 200% 300% 1 $11,770 $23,540 $35,310 2 $15,930 $31,860 $47,790 3 $20,090 $40,180 $60,270 4 $24,250 $48,500 $72,750 5 $28,410 $56,820 $85,230 6 $32,570 $65,140 $97,710 7 $36,730 $73,460 $110,190 8 $40,890 $81,780 $122,670 9 $45,050 $90,100 $135, $49,210 $98,420 $147,630 Calculatin Prcess: 6

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