It shall be the policy of University Health Services, Inc (UHS/UH) to establish a standard to determine the financial status of its patients for the purposes of identifying those in need of Indigent/Charity Care (ICCP). This determination is done with respect to hospital charges ONLY. This program will benefit all US citizens who are Georgia resident patients with income levels of 0% up to 200% of the Federal Poverty Guidelines with no other third party payor source. In order for a patient to be considered for the financial assistance program, the patient must have first applied for all other appropriate State or Federal programs.
No individual shall be denied a medically essential service based solely upon lack of ability to pay for services. All policies shall be implemented in accordance with all EMTALA and ICTF rules and regulations, as well as, any other federal or state law, rule or regulation as it relates to the delivery of health care services, as they currently exist and any future changes or amendments to these rules and regulations. Individuals shall be accorded impartial determinations regardless of race, creed, sex, national origin, handicap, or age.
All patients who seek reduced cost of care, give consent to use Personal Health Information data as well as financial data for consideration of assistance with the cost of their health care. The consent allows UHS to submit data requested by the Department of Community Health (DCH) to meet requirements for Disproportionate Share and Upper Payment Limit calculations.
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HOSPITAL POLICY RELATED TO PUBLIC SERVICE
- University Hospital is a public hospital committed to public service. No one seeking emergency services, including labor, will be turned away because of his/her inability to pay.
- University Hospital will make the decision on the most cost-effective method of service that is appropriate for those who are unable to pay. If follow-up visits have been established with one of the Primary Care Clinics and patients do not keep appointments then patient may forfeit their ICCP designation.
- University Hospital will participate as a hospital provider for Medicare and Medicaid Programs. University employees will be available during normal business hours on Monday through Friday (except Holidays or State Furlough Days) to assist individuals in determining eligibility for third-party programs. The unavailability of all or other means of meaningful compensation must be determined before indigent services can be considered.
- University Hospital must seek collections from all individuals with the ability to pay for hospital services. University will also seek collections on indigent patients that receive or would be eligible to receive third-party payments where proper credit to those funds is not attained due to the patient's failure to cooperate with the hospital or to cooperate with the third party programs in determining patients' eligibility for these third party programs.
- As stated above, no one seeking emergency services from University Hospital will be turned away because of their inability to pay for services. While the indigent care program described herein is primarily structured to benefit residents of Georgia, all patients presenting to the emergency room, labor and delivery triage, and to the UH Outpatient Clinic will be treated according to their individual needs and assessed as to their ability to pay for services, including eligibility for third-party programs.
- University's Patient Financial Services Department will keep a record of all amounts written off to Indigent Care. Once the obligation (85% of the Trust Fund payment less adjustments minus the amount transferred or deposited to the Trust Fund by or on behalf of the hospital, at a cost to charge ratio of 65%) has been met within the fiscal year, UHS may decline further eligibility under the Indigent Care Trust Fund for the remainder of the fiscal year. The Chief Financial Officer makes the final determination to decline further eligibility under the Indigent Care Trust Fund.
- University's Patient Financial Services Department will coordinate the training for DFACS, Access Services, and other areas as appropriate.
- The following services are not eligible for UHS's Indigent/Charity Programs:
- Elective or cosmetic procedures - an elective procedure is a procedure which Georgia Medicaid would not cover if the patient was a Medicaid beneficiary. (Note: if precerts are required for Georgia Medicaid to cover service then service may not be covered) Georgia Medicaid does not pay for cosmetic services.
- Items and services not included in UHS's Charge Description master (CDM)
- Services required as a result from a criminal act, while incarcerated, or in the custody of any law enforcement.
- Professional fees from a physician
- Private room differences
- Medicaid co-pay
- Accounts that are covered under liability or worker's compensation with no proof of denial of coverage.
- All services related to self inflicted injuries
- Other services as amended from time to time
APPLICATION PROCEDURES FOR RECEIVING INDIGENT CARE (ICCP)
- The Access Coordinator will require an application from every eligible person who claims inability to make the required minimum payment at service date and document any refusal in the computer system. The appropriate UH Financial Counselor will interview the patient to determine if the patient is eligible for any meaningful third party insurance program. If the patient is deemed ineligible for any meaningful third party insurance program, the Financial Counselor will initiate an application and instruct patient to see UHS Department of Family and Children's Services (DFCS) Caseworkers. UH does not accept or process applications for patients who have not received nor are scheduled to receive UH services. Applications for this program are only to be taken when a patient accesses UH services. UH ICCP is not an insurance card that you apply for in the event that you may need services. UH ICCP is a process where by UH will give consideration to discounting your medically necessary service charges if you meet the ICCP criteria. UH ICCP designation is a last resort. Note: If patient has been in an accident and an insurance should cover then patient is denied for services which should be covered by the accident insurance. Please note on ICCP if illness not related to accident so that ICCP application can be considered for that non-accident related service.
- UHS DFCS will work in conjunction with UHS criteria to determine Indigent eligibility. UHS DFCS will establish financial eligibility at the time of application if possible, but no later than sixty (60) days. If applicant has not contacted or is not making progress on completing the ICCP application by day 30 from date of services then UHS DFCS will issue a denial letter outlining the reason(s) for the denial. Applicant will have the remainder of the 60 days to complete the application process.
- If a patient is deemed eligible for SSI/disability, UH Finance Counselors (or their representative) will process an SSI/disability application. If SSA's final decision is that the patient is not disabled and subsequently denies their SSI/disability application, the patient will be eligible to apply for the UHS Indigent/Charity Care Program. If County DFCS or SSA denies an applicant for fraud (i.e. welfare fraud, etc.) or procedural reasons, (i.e. failure to keep assigned appointments, failure to provide required documentation, failure to meet given time frame requirements, etc.), an application for the UHS Indigent/Charity Care Program may be excluded from further consideration. If an applicant who is approved for indigent status is subsequently denied SSI eligibility by SSA for any reason other than the patient is found to be not disabled; their indigent status may be revoked and or future application excluded from consideration.
- University/DFACS will advise in writing and/or by the Indigent/Charity Care Adjustment reflected on the patient's hospital bill.
- The patient or responsible party must exhaust all necessary steps to secure payment from all other sources (Insurance, Medicare, Medicaid, no-fault, etc.) Applicant must apply to and be denied by all other possible financial resources before the patient will be considered for charity assistance. If patient refuses to apply or provide information necessary to the application process, ICCP will be terminated.
- The patient must inform UH of any changes in status such as residency, income, insurance eligibility, or marital status within 30 days of status change.
- An electronic version of the "Notifications to DFACS of Change in Patient Status" form will be generated to notify the Patient Financial Services Department and DFACS for any patients with indigent status or pending status who have moved outside of the State of Georgia or present at registration point with any kind of medical insurance.
- Applicants must conduct themselves in a courteous, cooperative manner. Failure to do so can result in termination in the ICCP program.
- For ER self-pay patients, UH may chose to determine patient's indigent status with the assistance of an electronic eligibility system. Claims will be billed an initial statement and one bill. The bill will denote that Indigent assistance may be available. Patient may elect to apply for ICCP at that time. Claims written off through the use of the electronic eligibility system patients will not receive other messages or bills.
FINANCIAL ELIGIBILITY DETERMINATIONS
- Informing Patients of Availability of Financial Assistance: Patients will be informed of available assistance by the following methods:
- Signs will be posted in the Emergency Room, Clinics, Admissions, and Business Offices, which state "Do You Need Help With Your Hospital Bill?".
- If the patient is unable to make the minimum required payment, the Access Coordinator will require a preliminary indigent/charity application.
- The appropriate UH Financial Counselor will interview the patient to determine if the patient is eligible for any third party insurance program. If the patient is deemed ineligible for any meaningful third party insurance program, the Financial Counselor will initiate an application and schedule an appointment for the patient with DFACS.
- DFACS will interview patients who have little or no third party coverage and will inform the patient of available assistance once they have determined the patient has little or no ability to pay.
- The patient will be informed of eligibility in writing by DFACS immediately upon determination.
- Residency and US Citizenship Requirements: A formal indigent care application will be accepted for hospital services for any US Citizen who is a resident of the State of Georgia. Proofs of residency will be required to verify six (6) months residency in the State of Georgia. Below are examples of acceptable proofs of residency:
- Employment check stubs showing patient's (or responsible household members) address during the last 6 month's period
- Utility bills or payment stubs showing current county address (one current and one at least 6 months old)
- Rent receipts for the last six months, a lease, or a statement by a rental agency or established real estate business that the patient has resided in Georgia for the last 6 months
- If a student, grade reports covering the last 6 months
- If homeless: Bring statements of residency for the last 6 months from the patient and two other people, one of whom must be a minister with a Georgia congregation or the Director of a private relief organization such as the Salvation Army
- Valid Georgia driver's license, showing a Georgia address, issued at least 6 months previously
- Other appropriate proofs of residency may be considered in addition to or in lieu of those stated above.
- US Citizen proof may consist of State government issued Certified Birth Certificate or Passport, Certification of Citizenship, etc.
- Responsible household members will be determined as follows: Persons legally married, legally responsible parents/guardians for children, parent(s) and relative(s) of students who are living at the home during school breaks, and other individuals who provide living arrangements for the applicant. Separated spouses must provide proof of legal separation to be considered as single applicant. If spouses are separated for more than 1 year then applicant will be treated as married.
- Income Determination and Payment Classification: Total gross income for the previous twelve months (12) and/or total gross income for the previous three (3) months will be used to determine annual income. (Gross Income is defined as total cash received from all sources before taxes or other deductions for all the responsible household members. Examples of commonly overlooked income include child support, social security, unemployment income, alimony, interest earned, insurance or annuity payments, trust funds, etc.). Applicants who have no income must provide evidence of how they are surviving day-to-day..
- Notification of Payment Classification: Patients will be notified immediately upon approval for indigent services by the DFACS person making the determination. The notification will be in writing, and by the Indigent/Charity Care Adjustment reflected on the patient's hospital bill.
- Assets: Real property value must not exceed 10 times the monthly poverty level for the appropriate household size. An individual's assets will be assessed to realistically determine the extent to which personal resources can help pay a hospital bill. While it is not our intent to strip a person of his/her resources to pay hospital bills, resources will be used as far, as is reasonable to avoid becoming a burden to other patients.
Applicant's assets will be determined as follows: Applicants must list all assets on applications. The amount of $125,000 will be allowed for primary residence (per county tax assessment) and $15,000 for combination of all vehicles (trucks/cars/motorcycles) using the Kelly Blue Book for value determination. Excess value over these amounts will be used in the asset calculation. All household assets will be taken into consideration including but not limited to: checking and savings accounts, ownership of homes and properties, vehicles, boats, ATV's, planes, livestock, IRAs, trust funds, retirement accounts, estates in probate, investments, etc. Failure to disclose all assets may result in a denial of the application and applicant can be held responsible for any service dates previously approved for ICCP. Note: When applicant transfers asset(s) to another, if transfer of asset more than 3 years prior to application then process as if asset was not patients and if transfer of asset less than 3 years prior to application process then process as though asset was patients
- *Co-Payments: The co-payment serves three useful purposes: 1) It helps prevent abuse of the system for providing uncompensated care to needy patients, 2) It allows the patient to maintain a measure of dignity by sharing in the cost of his/her care, and 3) It aligns the Indigent program with the Medicaid Program.
|Federal Poverty Guideline
|Emergency Room (no request for payment until after service
*Unless otherwise specified by other program participation (example: Ryan White)
Patient is asked to pay but patient will not be billed for Co-insurance.
- Collection Services: Accounts turned over to a collection service are beyond the jurisdiction of UH DFACS, and inquiries regarding such accounts should be referred to UHS's Patient Financial Services office at the Business Center. Patients may be determined eligible for uncompensated services even though collection action has been initiated.
- Elective Admissions/Procedures: Elective admissions/procedures will be denied if not covered by a third party source or if the patient is unable to make satisfactory payment arrangements. All elective admissions/procedures will be classified as "Full Pay". An elective admission/procedure is a procedure or admission that would not be covered by Georgia Medicaid if the patient was a Georgia Medicaid beneficiary; this includes services that Georgia Medicaid requires pre-certification, as well.
- Denials, Appeals and Re-applications: Patients denied financial assistance or whose financial assistance is revoked will be notified and may acquire a written notice at the University Hospital Patient Accounts office in the Business Center at the corner of Walton Way and 13th Street which also advises him/her of the right to appeal UHS's decision. All appeals for indigent care consideration must be received in writing thirty (30) days from the original denied date to the Director of Patient Financial Services or his/her appointed staff. Applicant will need to provide additional supporting information to be considered along with the appeal. All applicants denied for ICCP are unable to reapply for a minimum of three (3) months. When applicant has been denied due to income---any change in applicant status (family size, living conditions, and finances) then applicant may notify ICCP CASE MANAGERs & ICCP CASE MANAGERs may apply changed information for qualifying applicant as indigent if with in the 60 days of application/visit.
- Reporting of Indigent Care: Reports may be produced on request to identify patients receiving indigent care. Reports will identify patient, account number, date of service, type of service received, total charges, third party payments, co-payments, amount of indigent care write off, patient's county of residence, and employer (if any). Once patient has received Indigent Status and taken advantage of UHS's Indigent policy, patient cannot refuse consent for use of Health Information. If patient refuses consents or withdraws consent then account will be reactivated and full collection efforts will begin. In addition patient may be barred from future participation in indigent care program.
- Policy Compliance: In all instances, this policy is intended to comply with all requirements of the Indigent Care Trust Fund and related guidelines.
ETHICAL AND FAIR BILLING PRACTICES
- Payment of Hospital Charges:
- UHS will provide needed medically essential services to any patient regardless of his/her ability to pay.
- The "Consent Form for Medical Treatment" will outline to the patient or responsible party the Hospital's expectations regarding payment of bill.
- Payment Resources:
- Patients who express inability to pay or who request assistance will be informed of payment resources by a UH Financial Counselor, including, but not limited to, the following: Continuation of Insurance under COBRA Laws, auto medical pay benefits, or other liability type insurance, State Cancer Aid funding, Vocational Rehabilitation Program, Maternal & Infant Care Grant program, Medicaid, or other available local, state or federal programs.
- Department of Family and Children's Services (DFACS) will interview and evaluate patients to identify eligibility for such payment resources and will assist the patient with applications to the extent possible.
- Financial Assistance - Uncompensated Care:
- Patients who express an inability to pay will be evaluated to determine eligibility for uncompensated care. (See FINANCIAL ELIGIBILITY DETERMINATIONS above).
- Uncompensated Care Policy is intended to support the Georgia Medicaid program with requesting a minimum co-pay amount.
- Patients who believe they were unfairly denied uncompensated care may appeal the decision as outlined in Section E below.
- Payment Arrangements - Payment Plans:
- Patients who are financially able to pay their bills, but who cannot pay the full amount at one time will be informed of alternative payment methods.
- Charge card, a monthly payment plan, or a payroll deduction plan if employer allows may make payment of the bill.
- The monthly payment plans and payroll deductions, the patient will be provided with a disclosure statement/form; the statement/form will comply
with laws relative to Truth in Lending and Regulation Z disclosure requirements. UHS reserves the right to provide payment plans.
- Explanation of Charges or Cost:
- Explanation of charges for services is provided on request and every reasonable effort is made to respond to any concerns by patients about billing
- In compliance with state and federal regulations, incorrect charges or charges not supported by medical record documentation will be removed from the patient's bill. Patient accounts are routinely audited to review the accuracy of charges and to protect against systemic billing issues.
- An itemized statement of charges to include description of service and the date service was provided will be given to patient's and third party payers upon request.
- Billing / Charging Complaints:
- Patients are mailed monthly statements which provide the Customer Service department's phone number as a point of contact for assistance with questions, billing problems, etc.
- The patient's initial statement as well as the monthly statements contain information outlining the procedures to follow with regard to suspected errors, charges, or questions about their bill.
- Immediate effort is taken by staff of the appropriate Patient Accounting Services to address all inquiries or complaints originating from patients.
- The staff member will communicate with the patient by telephone or written correspondence to reach a satisfactory resolution of the patient's concern without negating the hospital's interest.
- Statement of Account:
- A monthly statement will be mailed to each patient when any amount is due from the patient.
- The monthly statement will contain a dunning message as outlined in the Patient Accounting System if the patient is liable for the bill. The statement also contains information outlining the procedures to follow with regard to errors, charges, or general questions about their bill.
- Accounts Transferred Out-for-Collections:
- Before any account is transferred out for collection, a "final notice" will be mailed to the patient warning that the account is about to be placed with an outside agency.
- Full collection efforts will be exercised to attempt payment.
- The right of the patient to personal visual and auditory privacy will be honored at all times during admission, outpatient registration, and /or financial interviews.
- The patient may have a family member or other representative present during any financial interviews conducted by UHS staff.
- Individuals not involved with the patient's finances will not be present during any interview without the patient's consent.
- The right of the patient to confidentiality will be honored, within the limits of the law at all times.
- The patient's bill, medical records, or other documents related to the patients' finances or treatment will not be released to any third party except as permitted or required by law.
- Patient information will not be shared in an unauthorized manner and will be maintained in the strictest confidence and utilized only by hospital employees and business associates authorized to review and act on such information.
- Internal Error Reporting:
- Any UHS employee who discovers an error or inaccuracy in any claim for payment of healthcare services submitted to a patient, governmental program or other payer should alert his/her supervisor immediately, or call the UHS's Integrity Hotline at 706-774-8536.
- The Board of Directors for University Health Care System assures the protection of all employees against any type of reprisal for good-faith reports of suspected or actual violations of our billing system.
All patients have the right to an appeal process if they feel UHS has denied services, or financial requirements are too stringent. In the event of medical care denial of indigency status the patient must make appeal in writing thirty (30) days from original denied date to the Patient Financial Services Department.
The Director of Patient Financial Services or his/her appointed staff will review the applications and make a determination on the appeal. The Appeal determination will be communicated to the patient by mailing a written determination to the address provided by the patient.
USE OF INDIGENT PATIENT DATA
- The financial Assistant/Patient Accounting Staff may/will keep a record of all amounts written off to Indigent Care.
- Reports may be produced on request to identify patients receiving indigent care. Reports will identify patient, account number, date of service, type of service received, total charges, co-payments, third party payments, amount of indigent care write off, patient's county of residence, and employer (if any).
- Once patient has received Indigent Status and taken advantage of UHS's Indigent policy, patient cannot refuse consent for use of Health Information for reporting to state UHS's Indigent Care. If patient refuses consent or withdraws consent then account will be reactivated and full collection efforts will begin.