Financial Assistance Eligibility Policy
Notice of Nondiscrimination: Health Pointe complies with applicable Federal civil rights laws and does not discriminate on the basis of race, color, national origin, age, disability, or sex. Health Pointe does not exclude people or treat them differently because of race, color, national origin, age, disability, or sex. See Attachment A for the complete notice of nondiscrimination as well as availability of language assistance.
To outline the process for making a reasonable determination of who is eligible to receive financial assistance at Health Pointe. To communicate the availability of financial assistance to patients and the public and to ensure that comparable guidelines are applied to requests for financial assistance, regardless of the Health Pointe location where the patient service is provided.
This Health Pointe Financial Assistance Eligibility Policy will be administered by appropriately designated Health Pointe personnel as outlined in supporting Financial Assistance Eligibility Procedures.
3. Policy Content
Health Pointe will eliminate patient financial responsibility for emergent or medically necessary care in situations where the patient/guarantor qualifies under the financial hardship guidelines, set forth in Section 6.6 below, and cooperates with Health Pointe in the administration of its Financial Assistance Eligibility Procedures. A good faith determination of financial need must be made prior to any waiver of charges.
Emergent or medically necessary care will be the basis for treatment, not financial obligation. Medical necessity will be determined by the treating physician. Determination of financial assistance will be given based on demonstrable financial need and will be granted in cooperation with the patient/guarantor whenever able. All patients/guarantors applying for financial assistance will be subject to the same financial assistance process regardless of primary payer. Consideration for financial assistance may not be given for services relating to experimental/research studies, elective services or bariatric surgical procedures.
To uphold our mission of improving the health of the communities we serve, Health Pointe will limit consideration for financial assistance to applicants that reside within the communities we serve. Exception may be made to patients seeking emergent or medically necessary care not available within another healthcare provider’s service area.
- Prior to seeking financial assistance, the patient/guarantor and Health Pointe will pursue all reasonable forms of third party payment as further outlined in Section 6.3.
- It is Health Pointe’s policy to require payment in full for non-emergent or non-medically necessary care including but not limited to experimental/research studies, elective cosmetic services and bariatric surgical procedures prior to service or when a statement is first presented, unless other approved arrangements for payment have been made.
- Patients/guarantors who identify that they are financially unable, or have been identified by Health Pointe as potentially financially unable, will be referred to the appropriately designated Health Pointe personnel for evaluation, as applicable. Health Pointe personnel may then proceed with the financial assistance application process to determine if there is demonstrated inability to pay. The patient/guarantor may be asked to complete a financial assistance application. A credit report may be obtained to verify information provided on the application, but will not be used to make a determination as to financial assistance eligibility. Portions of or the entire financial application process may be waived for certain patients/guarantors who presumptively qualify for financial assistance and are subsequently verified, consistent with Health Pointe policies and procedures. Examples may include individuals deemed homeless or deceased without an estate.
- If, as a result of the financial application process, assistance criteria are not met, the patient/guarantor will be advised to arrange payment according to the Health Pointe Patient Responsible Balance Billing and Collection Policy and applicable procedures, under which a patient/guarantor may qualify for discounts and/or other payment options such as prompt pay discounts, payment plans, etc.
- If it appears that financial hardship guidelines may apply, the patient/guarantor may be asked to supply supporting documentation and the application will be processed accordingly.
- The patient’s account will be documented with results of the determination. Reasonable efforts will be made to inform the patient/guarantor in writing of the determination (including, if applicable, the assistance for which the individual is eligible) and the basis for the determination.
- All applicable and supporting documentation for applications will be retained in accordance with the Record Management, Retention and Destruction Policy.
Third Party Payment Sources
Prior to seeking financial assistance, the patient/guarantor and Health Pointe will pursue all reasonable forms of third party payment including but not limited to Medicaid and enrollment in the Health Insurance Marketplace.
Health Pointe reserves the right to investigate, verify, interview and request assignment of:
- All benefits from any third party insurance source;
- All benefits from state or federal assistance programs for which the patient/guarantor may be eligible;
- All benefits from any charity organization; and/or
- Pending litigation.
Financial assistance is the account resolution process of last resort. As such, a patient/guarantor must fulfill all responsibilities under any of the above applicable programs or use available personal resources prior to qualifying for financial assistance. A patient/guarantor’s failure to produce the requested information or participate in one of the above programs may result in denial of financial assistance.
Availability of Financial Assistance
Health Pointe has implemented measures to widely publicize communications to patients and the public regarding the availability of financial assistance. Communication methods include but are not limited to signage in each hospital emergency department, admissions office(s) and other public locations, as well as information on the Health Pointe website (as referenced in Section 6.5). In addition, Health Pointe will offer a plain language summary of its Financial Assistance Eligibility Policy as part of the patient intake and/or discharge process, as well as provide individuals with assistance in completing the application process.
Patients will be notified of the Financial Assistance Eligibility Policy for a period of at least 120 days from the date of the first post-discharge billing statement. Patient balances will be eligible for financial assistance evaluation for at least 240 days from the date of the first post-discharge billing statement (“Application Period”). If Health Pointe receives a financial assistance application during the Application Period, whether the application is complete or incomplete, it will suspend any collection efforts until a determination regarding financial assistance is made.
Patients receiving care at a National Health Service Corps (“NHSC”) approved practice site or a Michigan State Loan Repayment Program (“MSLRP”) approved practice site will be evaluated for financial assistance based on the NHSC requirements of income and family size and will not be evaluated based on other factors.
Financial Assistance Identification and Application Process
The goal of the financial assistance eligibility process is to determine the patient/guarantor’s ability to pay.
A free copy of the Financial Assistance Eligibility Policy, as well as the current financial assistance application and a plain language summary of the policy, are available at all Health Pointe locations, at www.health-pointe.org/financialassistance, by calling (800) 968.0145 or emailing a financial resource advisor at FinancialCounseling@Health-Pointe.org. Each individual may be required to complete a financial assistance application and provide the information Health Pointe has requested as part of the application. Health Pointe determines financial assistance based upon the financial hardship guidelines set forth in Section 6.6. Health Pointe may require copies of pay stubs, federal income tax returns and any other income and asset verification sources. Technology may be utilized to assist in proactively and efficiently identifying patients who qualify for assistance or to automate the process of obtaining necessary data and analysis of ability to pay. Applicants may be requested to assist and cooperate in applying for benefits from third party insurance, state, federal or other charitable programs previously mentioned in Section 6.3 above.
Health Pointe may delegate determination of financial assistance eligibility to partner organizations in an effort to avoid duplication of efforts. Partner organizations will mirror the guidelines of this policy for qualification purposes, or by nature of the population they serve, will have met the minimum requirements. When delegation does occur, Health Pointe will periodically review the determining organizations’ documentation to ensure compliance with this policy.
Financial Hardship Guidelines Qualifications
In determining financial assistance eligibility, Health Pointe will evaluate the patient/guarantor’s ability to reimburse Health Pointe for the services being requested or previously rendered. Spectrum Health will evaluate information such as the following:
- Income levels
- Net worth
- Employment status
- Other financial obligations
- Amount and frequency of healthcare bills
A credit report may be obtained to validate information. Health Pointe will use the current U.S. Federal Poverty Guidelines (FPG) as a basis for income eligibility qualifications. Qualifying income for elimination of all financial liability (free care) for amounts otherwise owing will be 250 percent of poverty as defined by the current FPG (see http://aspe.hhs.gov/poverty/index.cfm for the current guidelines) as published annually by the Department of Health and Human Services.
Patients receiving care at a National Health Service Corps (“NHSC”) approved practice site or a Michigan State Loan Repayment Program (“MSLRP”) approved practice site who are 250 percent of the poverty level (found at the link in the above paragraph) will receive elimination of all financial liability (free care) for the services provided at the NHSC or MSLRP approved site consistent with the sliding fee discount program. As such, no sliding fee discount (schedule of fees for services) is applicable.
Financial records pertaining to the patient/guarantor’s household income may also be requested, not to assign responsibility to a third party, but rather to determine how they directly affect the applicant’s financial situation. Household, as defined by the United States Census Bureau, is a group of two or more related family members, whether by birth, marriage, adoption, or otherwise, who live together (non-relatives, such as housemates, do not count); all related persons living in the same household are considered members of one household. Health Pointe does not consider individuals living in one home but separately sole supporting as a combined household. A temporary living situation as a result of a medical condition will also not apply.
A patient’s clinical, behavioral and/or social history shall not be considered in assessing ability to pay.
To assure uniform application of this policy within Health Pointe, the following applies to all applicable Health Pointe facilities:
- All charges will be recorded on the patient’s account in accordance with the normal charging procedures. Although charges are the basis for billing and collection record keeping purposes, costs (not charges), will be the primary reporting unit for valuing financial assistance.
- Services will not be “downcoded” to a lower fee.
- “Professional courtesy” will not be utilized.
- Health Pointe will not discriminate on the basis of race, color, national origin, citizenship, sex, religion, age, disability, political beliefs, sexual orientation, and marital or family status.
- Patients meeting the criteria of this policy and who are approved for financial assistance will be eligible for free emergent or medically necessary care during the approval period outlined in Section 6.9. Because Health Pointe does not charge any amount to patients eligible for financial assistance under this policy, Health Pointe is fully compliant with the “amounts generally billed” and less-than-gross-charge limitations that apply to charitable hospitals.
Application Approval Process
- All financial assistance determinations must be approved by the appropriate personnel as outlined in the Financial Assistance Eligibility Procedures.
- Supporting documentation should accompany all financial assistance adjustments and be retained as referenced in Section 6.2.7 above.
All financial assistance application approvals made under the Financial Assistance Eligibility Policy may be effective for a period of at least 90 days and include subsequent emergent or medically necessary care. A change in financial situation or the addition of third party payer eligibility may alter the approval period and require further review.
Individuals who are denied financial assistance under the provisions of the policy may request a review of the determination. Reviews will be performed at the next level of authority for approval. Appeals progressing above the level of management within Patient Finance are taken to a panel of Health Pointe senior leadership selected by the Health Pointe Corporate Controller or his/her designee.
Collection Efforts in the Event of Nonpayment
In the event a patient/guarantor does not apply for or qualify for financial assistance under this policy, the collection actions Health Pointe may take in the event of nonpayment are more fully described in its Patient Responsible Balance Billing and Collection Policy. A free copy of this policy can be obtained by are available at all Health Pointe locations, at www.heatlh-pointe.org/financialassistance by calling (800) 968.0145 or emailing a financial resource advisor at FinancialCounseling@Health-Pointe.org. A separate written notice will be provided to each individual at least 30 days prior to any collection actions being initiated.
Basis for Calculating Amounts Generally Billed (AGB)
Health Pointe uses the look back method based on claims allowed by Medicare fee-for-service during a prior twelve month period to determine Amounts Generally Billed (AGB).
Health Pointe does not bill or expect payment of gross/total charges from individuals who qualify for financial assistance under this FAP.
Health Pointe reserves the right to alter, amend, modify or eliminate this policy at any time without prior written notice. All revisions to any attachments to this policy have been delegated to the Senior Director of Patient Financial Operations.
Notice of Nondiscrimination:
Health Pointe complies with applicable Federal civil rights laws and does not discriminate on the basis of race, color, national origin, age, disability, or sex. Health Pointe does not exclude people or treat them differently because of race, color, national origin, age, disability, or sex.
- Provides free aids and services to people with disabilities to communicate effectively with us, such as:
- Qualified sign language interpreters
- Written information in other formats (large print, audio, accessible electronic formats, other formats)
- Provides free language services to people whose primary language is not English, such as:
- Qualified interpreters
- Information written in other languages
If you need these services, contact Health Pointe Language Services at: 616.267.9701 or 1.844.359.1607 (TTY:711)
If you believe that Health Pointe has failed to provide these services or discriminated in another way on the basis of race, color, national origin, age, disability, or sex, you can file a grievance with:
616-935-6398; toll free: 1-833-706-4516
You can file a grievance in person or by mail, fax, or email. If you need help filing a grievance, the Director of Patient Experience is available to help you.
You can also file a civil rights complaint with the U.S. Department of Health and Human Services, Office for Civil Rights electronically through the Office for Civil Rights Complaint Portal, available at https://ocrportal.hhs.gov/ocr/portal/lobby.jsf, or by mail or phone at:
U.S. Department of Health and Human Services
200 Independence Avenue SW, Room 509F, HHH Building
Washington, DC 20201
1-800-368-1019, 800-537-7697 (TDD).
Complaint forms are available at http://www.hhs.gov/ocr/office/file/index.html.
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