501(r) Lessons Learned - Great Lakes · PowerPoint Presentation Author: Kelly Turner Created Date:...
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plantemoran.com Aaron Fields, MHA 501(r) Lessons Learned
Transcript of 501(r) Lessons Learned - Great Lakes · PowerPoint Presentation Author: Kelly Turner Created Date:...
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Aaron Fields, MHA
501(r) Lessons Learned
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Agenda
1. Introduction to 501(r)
2. Story Time with Aaron
3. A Dozen Lessons Learned
4. Pirates
5. Questions
2
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Introduction to 501(r)
• New IRS rule from the ACA
• December 29, 2015
• 4 Major Components
• CHNA
• Financial Assistance Policy
• Amounts Generally Billed
• Billing and Collections
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Primary Goals of Federal Policy Makers
Ensure patients and the
community at large are aware
that financial assistance is
available
FAP-eligible patients pay no more than the
average insured patient
Ensure patients & community
understand the process
Require tax-exempt hospitals
check FAP eligibility prior to undertaking any
ECAs
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Storytime
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A Dozen Lessons Learned #12 –Presumptive Eligibility: Inform your patients
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#11 - Signage
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#10 – Covered Provider List: Appendix and Group Names
Example:
ABC Hospital Client
• Exhaustive List of Covered and Non-Covered Individual Providers
• Resulted in an 18 Page Appendix to the FAP
Switched to Group Names
• Reduced Appendix Down to 4 Pages
• Reduces Long-Term Upkeep of the List
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#9 – Documentation
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#8 – Headings for the FAP
Use Headings in FAP that match sections of 501(r)
1. Methods of Applying for Financial
Assistance
2. Eligibility Criteria
3. Limitation on Charges
4. Measures to Widely Publicize the
FAP
5. Actions that may be taken in the
Event of Non-Payment
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#7 – Add Language that Attests to Compliance
“ XYZ Hospital is in compliance with the 5-percent/1000 person threshold for translated copies the HHS Guidance safe harbor and 501(r) final regulations because there was not a population with English as a second language that met either threshold.”
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#7a – Translated Copies on your Website
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#7a – Translated Copies on your Website
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#6 – Review your 990 Schedule H Answers
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#5: Who does the AGB apply to?
OBAMACARE
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#5a: Who does the AGB apply to: Sample Calculation
Insurance 80/20 coverage Insurance 80/20 coverage
Deductible $2,000 Deductible $3,500
Hospital Bill $10,000 Hospital Bill $10,000
Deductible Paid $2,000 Deductible Paid $3,500
Remaining Bill $8,000 Remaining Bill $6,500
80% Insurance Payment $6,400 80% Insurance Payment $5,200
Remaining Patient Bill $1,600 Remaining Patient Bill $1,300
Total Patient Portion $3,600 Total Patient Portion $4,800
AGB Amount $4,500 AGB Amount $4,500
Result No Discount Result $300 Discount
We Care Hospital: AGB is 45%
Patient BPatient A
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#4 – Billing Collections and the FAP
• If Separate Policy – Reference in the FAP
• Also if Separate – House in the Same Location on Website
• Add a List of Relevant Definitions
• Describe Billing Process in Steps that Reflect Compliance
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#3 – Billing and Collections Timing
NOTIFICATION PERIOD 120 DAYS
240 DAYSAPPLICATION PERIOD
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#2 – Measures to Widely Publicize
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#1 – Education: Who needs to know?
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