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Tag: FAP

COVID-19 UNCOMPENSATED CARE RECOGNITION SERVICES – Hospital Financial Assistance Policy Update

Hospitals should ensure Financial Assistance Policy language reflects ALL forms of charity discounts.

Hospital Patient Financial Assistance Policy
As the healthcare industry prepares for COVID-19, hospitals may experience high volumes of care to the most critically vulnerable population of underinsured and uninsured patients.  CMS only recognizes, and reimburses, for this charity if it is articulated in the hospital’s patient financial assistance policy (FAP).  Toyon recommends hospital teams verify language in the FAP to be reflective of all forms of charity discounts under Medicare definitions.  

What should generally be in an FAP as Charity
Hospital patient financial assistance policies should not only specify charity care discounts as patient financial assistance, but also self-pay discounts (not related to prompt pay) and non-covered Medicaid as forms of charity care. 

Access to Healthcare Crisis FAP Language
In preparation for what could be an extraordinary demand on the healthcare system, Toyon has crafted the FAP language below.  This is draft template language to assist our clients.  Any language adopted by a hospital should follow the hospital’s approval procedure (approved by hospital leadership / board of directors). 

An Access to Healthcare Crisis must be proclaimed by [hospital leadership / approved by the board of directors] and attached to this patient financial assistance document as an addendum.  An Access to Healthcare Crisis may be related to an emergent situation whereby state / federal regulations are modified to meet the immediate healthcare needs of the hospital’s community during the Access to Healthcare Crisis.  During an Access to Healthcare Crisis [hospital / health system name] may “flex” it’s patient financial assistance policy to meet the needs of the community in crisis.  These changes will be included in the patient financial assistance policy as included as an addendum.  Patient discounts related to an Access to Healthcare Crisis may be provided at the time of the crisis, regardless of the date of this policy (as hospital leadership may not be able to react quickly enough to update policy language in order to meet more pressing needs during the Access to Healthcare Crisis).  

Please contact Fred Fisher at 888.514.9312, with any questions. 


Toyon Associates, Inc.

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COVID-19 President’s National Emergency Declaration CMS Fact Sheet

President’s National Emergency Declaration; CMS COVID-19 Fact Sheet
On March 13, 2020, the Centers for Medicare & Medicaid Services (CMS) published a fact sheet that outlines the impacts to healthcare providers from President Trump’s national emergency declaration. CMS is empowered to take proactive steps through 1135 waivers and rapidly expand the Administration’s aggressive efforts against COVID-19.
Overall, these regulatory changes are focused on addressing the potential shortage of beds needed to address the infected population. It appears that excess patient load may now be pushed into any available bed, including post-acute care settings by waiving patient and facility requirements. These changes appear to be effective immediately.
For more information regarding CMS Current Emergency response and issuances, use the link below:
Toyon’s Take on Hospital Charity Policies During the Emergency
As demand increases, providers should prepare for an influx of patients who are underinsured with high deductible health plans, or one of over 27 million Americans without health coverage. As hospitals care for these patients, it is important any corresponding patient discounts are specified in the patient financial assistance policy (FAP). If providers are loosening FAP requirements for care related to COVID-19 testing or treatment, it is recommended the FAP is updated to include this coverage. Specification in the FAP allows for uncompensated care cost recognition and payment for DSH providers.
Toyon is committed to keeping providers informed and will continue to send important updates as they unfold.


Toyon Associates, Inc.
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