Billing and Collections Policy and Procedures

Políticas y procedimientos de facturación y cobro

 

I.    PURPOSE

This policy applies to Sumner County Hospital District 1 and its employed medical partners (collectively “SCHD1”), and together with SCHD1’s Financial Assistance Policy (“FAP”) is intended to meet the requirements of applicable federal, state, and local laws, including, without limitation, section 501(r) of the Internal Revenue Code of 1986, as amended.  This policy establishes the actions that may be taken in the event of nonpayment for medical care provided by SCHD1, including but not limited to Extraordinary Collection Actions. This policy reflects SCHD1’s commitment to:

  1.     Treat all patients and Individual(s) Responsible equally and with dignity and respect, without regard to race, national origin, gender, age, or other characteristic;
  2.     Ensure appropriate billing and collection procedures are uniformly followed;
  3.     Ensure reasonable efforts are made to determine whether the Individual(s)Responsible for payment of all or a portion of a patient account are eligible for assistance under the Financial Assistance Policy; and
  4.     Provide clear and consistent guidelines for conducting billing and collection functions in a manner that promotes compliance, patient satisfaction, and efficiency.

II.    DEFINITIONS

  1.     Plain Language Summary means a written statement that notifies an Individual(s) that SCHD1 offers financial assistance under the FAP for inpatient and outpatient hospital services.
  2.     Application Period means the period during which SCHD1 must accept and process an application for financial assistance under the FAP. The Application Period begins on the date the care is provided and ends on the 240th day after the SCHD1 provides the first post-discharge billing statement.
  3.     Billing Deadline means the date after which SCHD1 or its designated collection agency may initiate an ECA against a Responsible Individual(s) who has failed to submit an application for financial assistance under the FAP. The Billing Deadline must be specified in a written notice to the Responsible Individual(s) provided at least 30 days prior to such deadline, but no earlier than 120 days after the first post-discharge statement.
  4.     Completion Deadline means the date after which SCHD1 or its designated collection agency may initiate or resume an ECA against an Individual(s) who has submitted an incomplete FAP if that Individual(s) has not provided the missing information and/or documentation necessary to complete the application or denied application. The Completion Deadline must be specified in a written notice and must be no earlier than the later of: (1) 30 days after SCHD1 provides the Individual(s) with this notice; or (2) the last day of the Application Period.
  5.     Extraordinary Collection Action (ECA) means any action against an Individual(s) responsible for a bill related to obtaining payment of a Self-Pay Account that requires a legal or judicial process or reporting adverse information about the Responsible Individual(s) to consumer credit reporting agencies/credit bureaus. ECAs do not include transferring of a Self-Pay Account to another party for purposes of collection without the use of ECAs.
  6.     FAP-Eligible Individual(s) means a Responsible Individual(s) eligible for financial assistance under the FAP without regard to whether the Individual(s) has applied for assistance.
  7.     Financial Assistance Policy (FAP) means SCHD1’s Financial Assistance Program  which includes eligibility criteria, the basis for calculating charges, the method for applying the policy, the measures to publicize the policy.
  8.     Responsible Individual(s) means the patient and any other Individual(s) having financial responsibility for a Self-Pay Account. There may be more than one Responsible Individual(s).
  9.     Self-Pay Account means that portion of a patient account that is the Individual(s) responsibility of the patient after application of payments made by any available healthcare insurance or other third-party payer (including co-payments, co-insurance and deductibles),  and application of any reduction or write-off after application of the FAP, as applicable.

III.    PROCEDURES

  1.    INSURANCE BILLING

  • Please note that it is the patient’s responsibility to know their insurance benefits and coverage prior to their services at SCHD1. All required referral(s) or authorizations must be secured prior to services. If you have questions regarding your financial responsibility or coverage of services at SCHD1, please contact your insurance carrier in advance of services.
  •     For all insured patients, SCHD1 will bill applicable third-party payers (as based on information provided by or verified by the patient) in a timely manner.
  •     If a claim is denied (or is not processed) by a payer due to an error on our behalf, SCHD1 will not bill the patient for any amount in excess of what the patient would have owed had the payer paid the claim.
  •     If a claim is denied (or is not processed) by a payer due to factors outside of our organization’s control, staff will follow up with the payer and patient as appropriate to facilitate resolution of the claim. If resolution does not occur after prudent follow-up efforts, SCHD1 may bill the patient or take other actions consistent with current regulations and industry standards.

   2.    PATIENT BILLING

  •     All uninsured patients will be billed directly and timely, and will receive a statement as part of the organization’s normal billing process.
  •     For insured patients, after claims have been processed by third-party payers, SCHD1 will bill patients in a timely fashion for their respective liability amounts as determined by their insurance benefits.
  •     All patients may request an itemized statement for their accounts at any time.
  •     If a patient disputes his or her account and requests documentation regarding the bill, staff members will provide the requested documentation.
  •     SCHD1 may approve payment plan arrangements for patients who indicate they may have difficulty paying their balance in a single installment.
  •     Patient Financial Services (PFS) supervisors and directors have the authority to make exceptions to this policy on a case-by-case basis for special circumstances.
  •     SCHD1 is not required to accept patient-initiated payment arrangements and may refer accounts to a collection agency as outlined below if the patient is unwilling to make acceptable payment arrangements or has defaulted on an established payment plan.
  •     Patient payments resulting in a credit balance may be transferred to other open patient account balances.

IV.    COLLECTIONS

All patients are given a reasonable period of time to fulfill their financial obligations, either through resolving the account with payment, establishing a payment plan, or by completing the FAP application. In compliance with relevant state and federal laws, and in accordance with the provisions outlined in this Billing and Collections Policy, SCHD1 may take any and all legal actions, including ECAs, to obtain payment for medical services provided.  However, SCHD1 will not engage in ECAs, either directly or by any debt collection agency or other party before reasonable efforts are made to determine whether a Responsible Individual(s) is eligible for assistance under the FAP. SCHD1 adheres to the following collections guidelines:

    A. All patients will be offered a Plain Language Summary and an application form for financial assistance under the FAP as part of the discharge or intake process from SCHD1.

    B. At least three separate statements for collection of Self-Pay Accounts shall be mailed or emailed to the last known address of each Responsible Individual(s); provided, however, that no additional statements need be sent after a Responsible Individual(s) submits a complete application for financial assistance under the FAP or has paid in full.  At least 60 days must have elapsed between the first and last of the required three mailings. It is the Responsible Individual(s) obligation to provide a correct mailing address at the time of service or upon moving. If an account does not have a valid address, the determination for "Reasonable Effort" will have been made.

    C. Statements of Self-Pay Accounts will include but not limited to:

  •     An accurate summary of the hospital services covered by the statement;
  •     The charges for such services;
  •     The amount required to be paid by the Responsible Individual(s) (or, if such amount is not known, a good faith estimate of such amount as of the date of the initial statement); and
  •     A conspicuous written notice that notifies and informs the Responsible Individual(s) about the availability of Financial Assistance under the SCHD1’s FAP including the telephone number of the department and website address where copies of necessary documents may be obtained.

     D.  At least one of the statements mailed or emailed will include written notice that informs the Responsible Individual(s) about ECAs that SCHD1 intends to take if the Responsible Individual(s) does not apply for financial assistance under the FAP or pay the amount due by the Billing Deadline. Such statement must be provided to the Responsible Individual(s) at least 30 days before the deadline specified in the statement. A Plain Language Summary will accompany this statement.

     E. SCHD1 will not initiate ECAs when the claim was denied due to a SCHD1 error. However, SCHD1 may refer the Responsible Individual(s) liability portion of such claims for ECAs if unpaid.

     F. Prior to initiation of any ECAs, an oral attempt will be made to contact Responsible Individual(s) by telephone at the last known telephone number at least once.  During all conversations, the patient or Responsible Individual(s) will be informed about financial assistance that may be available under the FAP.

     G. SCHD1 may pursue ECAs as follows:

           a. If any Responsible Individual(s) fail to apply for financial assistance under the FAP by 120 days after the first post discharge statement, and the Responsible Parties have received a statement with a Billing Deadline described above, SCHD1 or its designated collection agency may initiate ECAs.

           b.  If any Responsible Individual(s) submits an incomplete application for financial assistance under the FAP prior to the Application Deadline, then ECAs may not be initiated until after each of the following conditions have been met:

  •         PFS provides the Responsible Individual(s) with a written notice that describes the additional information or documentation required under the FAP in order to complete the application for financial assistance, which notice will include a copy of the Plain Language Summary.
  •         PFS provides the Responsible Individual(s) with at least 30 days’ prior written notice of the ECAs that SCHD1 or its designated collection agency may initiate against the Responsible Individual(s) if the FAP application is not completed or payment is not made; provided, however, that the Completion Deadline for payment may not be set prior to 120 days after the first post discharge statement.
  •         If the Responsible Individual(s) who has submitted the incomplete application completes the application for financial assistance, and PFS determines definitively that the Responsible Individual(s) is ineligible for any financial assistance under the FAP, SCHD1 will inform the Responsible Individual(s) in writing the denial and include a 30 days’ prior written notice of the ECAs that SCHD1 or its designated collection agency may initiate against the Responsible Individual(s); provided, however, that the Billing Deadline may not be set prior to 120 days after the first post discharge statement.
  •         If the Responsible Individual(s) who has submitted the incomplete application fails to complete the application by the Completion Deadline set in the notice provided, ECAs may be initiated.
  •         If an application, complete or incomplete, for financial assistance under the FAP is submitted by a Responsible Individual(s), at any time prior to the Application Deadline, SCHD1 will suspend ECAs while the FAP application is pending.

           c. After the commencement of ECAs, designated collection agencies shall be authorized to report unpaid accounts to credit agencies, and to file judicial or legal action, garnishment, obtain judgment liens and execute upon such judgment liens using lawful means of collection.  SCHD1 and its designated external collection agencies may also take any and all legal other actions, including but not limited to, telephone calls, emails, texts, mailing notices, and skip tracing to obtain payment for medical services provided.

V.    INFORMATION REGARDING FINANCIAL ASSISTANCE POLICY

All patients or Responsible Individual(s) may contact SCHD1 to determine possible eligibility regarding financial assistance for their accounts, payment plan options and other applicable programs.

For patients who qualify under SCHD1’s FAP, the amounts charged for emergency and other medically necessary care do not exceed amounts charged to patients with insurance coverage.  Allowable charges will be calculated by one of the following methods:

  1.     The average of the three lowest negotiated commercial rates;
  2.     The lowest negotiated commercial rate; or
  3.     Medicare rate.

SCHD1’s Financial Assistance Policy provides patients with information regarding:

  1.     Eligibility criteria for financial assistance from SCHD1;
  2.     Information regarding the availability of free or discounted care;
  3.     The basis for calculating amounts charged; and
  4.     The methods of applying for financial assistance.

Individuals with questions regarding SCHD1’s Financial Assistance Policy may contact the financial counseling office at 620-845-6492. Patients may obtain a copy of SCHD1’s Financial Assistance Policy free of charge: 

  1.     In person at Patient Financial Services at 601 S Osage, Caldwell, KS  67022 1654;
  2.     By calling Patient Financial Services at 620-845-6492; or
  3.     Online at www.sumnercountyhospital.org

IV. CUSTOMER SERVICE

During the billing and collection process, SCHD1 will provide quality customer service by adhering to the following guidelines:

  1.     SCHD1 will enforce a zero-tolerance standard for abusive, harassing, offensive, deceptive, or misleading language or conduct by its employees.
  2.     SCHD1 will maintain a streamlined process for billing questions and/or disputes, including a phone number patients and Responsible Individual(s) may call and an address they may write. This information will remain listed on all patient bills and collections statements sent.
  3.     After receiving a communication from a patient or Responsible Individual(s) SCHD1 staff will return phone calls as promptly as possible, but in any event, no more than two business days after the call was received.