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501(R) - 10 OBSERVATIONS AND REMINDERS
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Number 10 Amounts generally billed (AGB) is a benchmark not a required discount. If your FAP is written appropriately, your AGB should not impact the amount written off to charity care. Determining AGB percentage should be one of the first steps in a 501(r) compliance process.
Number 9 A hospital’s FAP, application for assistance, and plain-language summary must be translated to include LEP language groups that constitute 5% or 1,000, whichever is less, of the population of persons likely to be affected.
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Number 8 Reporting adverse information to consumer credit reporting agencies or credit bureaus is considered an extraordinary collection action (ECA). Utilizing a collection agency while maintaining ownership of the debt is not.
Number 7 A hospital’s FAP must include a list of outside providers, other than the hospital itself, delivering emergency or other medically necessary care in the hospital facility that specifies which providers are covered by the FAP.
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Number 6 A plain language summary of the FAP must be offered as part of the intake or discharge process. It must also be provided with other required notification at least 30 days prior to initiating an ECA.
Number 5 The FAP, FAP application form, and plain language summary of the FAP must be available on a Web site. The URL of the web site must be provided on Schedule H of the 990.
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Number 4 A hospital’s FAP must indicate that, following a determination of FAP-eligibility, a FAP-eligible individual may not be charged more than AGB for emergency or other medically necessary care.
Number 3 A hospital’s FAP must explain which method the hospital used to compute AGB. If the look-back method was used, the FAP must also state: • The AGB percentage • How the hospital calculated the percentage or explain how the public may readily obtain the information
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Number 2 A hospital’s financial assistance policy, billing and collections policy, and emergency medical policy must be approved by an authorized body (typically the governing body).
Number 1 Calendar year end hospitals should already be in full compliance with the regulations. Fiscal yearend hospitals should be in full compliance by the first day of the fiscal year beginning in 2016.
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QUESTIONS?
THANK YOU! FOR MORE INFORMATION Kevin Ensminger, Director
[email protected]
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