Methodist Billing and Collection Policy Community United Methodist Hospital Inc., a Kentucky nonprofit, faith-based, and tax-exempt healthcare system, operates Methodist Hospital, Methodist Hospital Union County and all clinics affiliated with those hospitals (collectively, Methodist ). Our mission is to provide high-quality, cost-effective healthcare services and to promote wellness in the communities that we serve. This Billing and Collection Policy (the Policy ) describes the process and timeframes used in Methodist s billing cycle and the collection activities that pertain to patient accounts with remaining balances. This Policy is intended to comply with the requirements imposed by Section 501(r) of the Internal Revenue Code of 1986, as amended (the Code ), and the regulations thereunder. Before engaging in Extraordinary Collection Actions, as defined below, Methodist will make reasonable efforts to assess a patient s eligibility for financial assistance under its Financial Assistance Policy (the FAP ). Copies of the Methodist FAP and the financial assistance applications can be found on Methodist s website, in Admissions and the Emergency Department registration at Methodist Hospital and Methodist Hospital Union County, as well as all clinics affiliated with those hospitals (each, individually, the Hospital ). A copy of the financial assistance application is located on the back of all billing statements/notices. As described in the FAP, financial assistance will be offered to patients who satisfactorily demonstrate financial need. This Policy will be effective upon adoption by the Board of Directors of Methodist. The Board will review this Policy annually. Definitions Amount Generally Billed ( AGB ) Amounts charged for emergency and medically necessary medical services to patients eligible for financial assistance, multiplied by the Hospital-specific percentage. Methodist will not charge FAP-eligible patients more than the amounts generally billed to individuals with Medicare or commercial insurance covering their care. Application Period: The period during which a patient may apply for financial assistance for his or her outstanding balance. This period may begin before the patient receives services, but it will end on the 240th day after the patient receives his or her first post discharge billing statement from the Hospital or its billing subcontractor. 1
Extraordinary Collection Action ( ECA ): Any action against an individual related to obtaining payment of an account that requires a legal or judicial process (including wage garnishment, levy, and liens on real property) or involves reporting adverse information about the patient to consumer credit reporting agencies or credit bureaus. Notification Period: The 120 days immediately following the patient s first post discharge billing statement. During this period, the Hospital will make reasonable efforts to inform the patient that he or she may be eligible for assistance under the guidelines of this Policy. The Hospital will not engage in any extraordinary collection activities during this period unless the Hospital has otherwise made reasonable efforts to determine whether the patient is eligible for financial assistance under the FAP. Payment Plan Methodist offers interest free payment arrangements to those with or without insurance. Payment Plans have a minimum monthly payment of $25. Patient balance is divided over 24 monthly payments. Policy Consistent with the FAP, an application for financial assistance will be offered to all patients. Except in emergency situations, a patient s photo ID and insurance card will be required for registration. For minors, only an insurance card is required. If no insurance card is presented, then the patient will be registered as self pay. Methodist staff will attempt electronically to determine eligibility of the insurance card that is presented. All known co-pays will be requested at time of service. Upon complete entry of the charge for service, insurance will be billed. Once payment, adjustment, denial, or patient inquiry is received the remaining balance will be turned over to patient responsibility and the billing cycle will begin. For those without insurance a 10% discount will be offered for services provided. Through the financial assistance process, Methodist will first assist the uninsured in obtaining Federal or State aid. If uninsured patients are unable to qualify for a medical insurance benefit, government entitlement program and/or any source with which Methodist participates, then they may be eligible for financial assistance as described in the FAP. For those uninsured patients who complete the financial assistance process but do not qualify, they will receive a 25% discount. This 25% discount combined with the 10% self pay discount will equal to a total of 35% discount available to self-pay patients. Individuals who qualify for financial assistance may be eligible for up to 100% discount. It is the responsibility of patient or their responsible persons to present accurate and correct information at registration. If an incorrect insurance card is presented at registration, as a courtesy to our patients, Methodist will refile your claim with the correct insurance as long as the claim falls within timely filing limits. If a patient is past the timely filing deadline for a claim, then the outstanding balance remains the patient s responsibility. Timely filing limits vary by insurance company and can be as short as 60 days from date of service and can be as long as 365 days from date of service. 2
Statement Cycle Once a balance is deemed to be a patient s responsibility, the statement cycle and the Notification Period will begin. During the Notification Period, the patient or responsible person will receive statements and notices as set forth below. On the back of each of these statements and notices is a copy of the financial assistance application and a message on the front notifies the patient or responsible party about the FAP. The First Statement - Following the patient s discharge, this statement will be mailed to the patient s last known address. This statement will offer a 20% prompt pay discount. This discount will apply to a patient s balance, with the exception of co-pays, that are fully paid within 30 days of date the statement is provided. Consistent with the FAP, this statement will include contact information for patients interested in speaking with a Methodist financial counselor to apply for financial assistance or to establish a Payment Plan. The Second Statement - Thirty days after the first statement is issued, a second statement will be provided. Consistent with the FAP, this statement will include contact information for patients interested in speaking with a Methodist financial counselor to apply for financial assistance or to establish a Payment Plan. The Third Statement Sixty days after the first statement is issued, a third statement will be provided. Consistent with the FAP, this statement will include contact information for patients interested in speaking with a Methodist financial counselor to apply for financial assistance or to establish a Payment Plan. The Past Due Notice Ninety days from issuance of the first statement, if no response has been received from the patient, a past due notice will be mailed. Consistent with the FAP, this statement will include contact information for patients interested in speaking with a Methodist financial counselor to apply for financial assistance or to establish a Payment Plan. This notice will serve as Methodist s ECA Initiation Notice, as defined below. Reasonable Efforts No ECAs will be pursued against any patient during the Notification Period or until after the Hospital has satisfied its reasonable efforts standard, as described below. The Hospital will have made reasonable efforts to determine whether a patient is FAP-eligible if it complies with the terms of this Policy and the FAP and (i) it determines that the patient is presumptively eligible for financial assistance as described in the FAP; (ii) it receives an incomplete application for financial assistance and notifies the patient about how to complete the FAP application, providing him or her with a reasonable opportunity to do so; or (iii) it receives and processes a completed application for financial assistance and determines whether the patient is FAP-eligible for the care. 3
Patients may submit an application during the Application Period. If an individual has not submitted an application within the Notification Period, then the Hospital may begin engaging in the ECAs described below after issuing the ECA Initiation Notice. If the Hospital receives an incomplete application form during the 240-day Application Period, it will suspend any ECAs being undertaken against the patient and provide the patient or his or her legal representative with a list of the missing information or documentation and give the patient 30 days to provide the missing information. The notice concerning missing information will include contact information for a Methodist financial counselor who can help the patient complete his or her application. If the patient does not provide the missing information within the specified period, the Hospital may commence (or resume) ECAs assuming it has provided the ECA Initiation Notice described above. Once the Hospital receives a completed application form with all supporting documentation, it will complete and document an eligibility determination in a timely manner. Once the eligibility determination is made, the patient will be sent a letter explaining the amount of financial assistance that will be provided, if any. If the patient is eligible for financial assistance, the Hospital will provide the patient with a billing statement showing the amount owed, how that amount was determined, and describe how the individual can learn more about how the Hospital calculates AGB. The Hospital must issue refunds to the patient if the patient previously paid an amount to the Hospital that exceeds what he or she should have been personally responsible for paying, unless such amount is less than $5 (indexed for inflation), or such other amount determined by the IRS. If the patient is eligible for financial assistance, the Hospital will also take all reasonable measures to reverse any ECAs taken against him or her. If the patient s account is not eligible for a full write off of the charges and the account is still in good standing with the Hospital, then the patient will be notified that he or she has the option to set up a Payment Plan to satisfy the remaining patient responsibility. Consistent with the FAP s discussion of appeal rights, if a patient believes his or her application for financial assistance was not properly considered, or he or she otherwise disagrees with the determination, a patient may submit a written request for reconsideration. Collection Actions The Hospital has the right to pursue collections directly or working with a third party collection agency. The Hospital will pursue collection actions against individuals determined to be ineligible for financial assistance, individuals determined to be eligible but who have received discounted (not free) care, or individuals who have failed to cooperate with the Hospital or who are not making payments in accordance with established Payment Plans. Before engaging in, or resuming, the actions mentioned here, the Hospital will issue a written notice that (i) describes the specific collection activities it intends to initiate (or resume), (ii) provides a deadline after which such action(s) will be initiated (or resumed), and (iii) includes a plain language summary of the FAP (the ECA Initiation Notice ). The Hospital will also make a reasonable effort to orally notify the patient about the FAP and how he or she can get help with the financial assistance application process. The Hospital may initiate collection activities no 4
sooner than 30 days from the date on which it issues the ECA Initiation Notice, either by mail or electronic mail. The Hospital may take the actions described below if a patient does not pay his or her medical bill timely: Each patient provided medical services by the Hospital will receive a total of three (3) billing statements and a past due notice, as described above, stating that all or a portion of the patient s bill may be eligible for forgiveness under the Hospital s FAP. If Medicaid or other governmental funding is unavailable, and payment arrangements are not made with the patient for paying the bill during the Notification Period, then the Hospital may refer patient files to an outside collection agency for processing and collection efforts. A patient s account will be sent to a collection agency only after it has been reviewed by a qualified Methodist employee to verify completion of the billing cycle and compliance with the reasonable efforts requirements. Once this review is complete, the account will be eligible to be turned over to a collection agency. Once referred, the collection agency is authorized to contact the patient to establish a plan for resolving the patient s debt. The collection agency is also authorized to report the negative status of the debt to credit bureaus. Once the collection agency has exhausted their collection efforts, those accounts are sent to an attorney who is authorized to take action against an individual to obtain payment of an account that requires a legal or judicial process (including wage garnishment, levy, and liens on real property). Once the legal process begins, accounts will be subject to court costs, prejudgment and post-judgement interest, and attorneys fees as ordered by the court. Consistent with the FAP, Methodist will make copies of this Policy widely available to the general public. 5