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, firstname.lastname@example.org with any questions.
Toyon Associates, Inc.