Date: November 13, 2015
To: Chief Financial Officers, Legal Counsel, Government Affairs, Public Policy Staff, WSHA Fiscal Assistance Workgroup and Lobbyists
From: Zosia Stanley, JD, MHA, Policy Director Claudia Sanders, Senior Vice President of Policy Development
Contact: Zosia Stanley, ZosiaS@wsha.org (206) 216-2511
Subject: Standardized Financial Assistance Application and Communication Plan
This bulletin provides information on two financial assistance documents that WSHA will recommend every hospital adopt:
- A standard financial assistance application form; and
- A standard plan for communicating the availability of financial assistance.
WSHA intends to recommend that all hospitals adopt the standard financial assistance application and communication plan once these documents are finalized and approved by the WSHA Board. These documents focus on the patient-facing portions of the financial assistance process and do not dictate the levels of financial assistance offered at individual hospitals.
All hospitals in Washington State.
WSHA recommends every hospital review this bulletin and the linked application and communication plan. These documents are still in draft form, and WSHA welcomes feedback by December 1, 2015. We plan to ask our Board to adopt finalized versions of these documents as a Washington standard at the Board’s upcoming meeting in early December. Upon finalization and approval by the WSHA Board, WSHA will ask all hospitals in the state to adopt and use this standard financial assistance application form and comply with the standard communication plan.
WSHA will host a members-only webinar on Monday, November 23, 2015 from 11:00am to 12:30pm to provide more information. The webinar will include a discussion of the impetus to develop standard documents and a review of the draft application form and communication plan. This is an important topic for all Washington State hospitals, and we encourage attendance from finance, legal, and government relations staff. Please contact Cliff Duggan if interested in attending. Cliff can be reached at CliffD@wsha.org or 206.216.2517.
Overview and Background
Patients and advocacy groups have expressed frustration with the financial assistance process at some hospitals and have asked for easier access to information about financial assistance. Specifically, patients and advocacy groups have expressed concerns that patients do not know financial assistance is available, do not think they are “poor enough” to qualify, find the application process confusing, and do not know who to contact with questions.
During the 2015 legislative session, WSHA worked with Representative Laurie Jinkins on House Bill 1504, which contained two main requirements on financial assistance. First, the bill required the Washington State Department of Health to establish a standardized financial assistance application form that every hospital in the state would be mandated to use to determine eligibility. Second, the bill mandated hospitals provide patients with notice of the availability of financial assistance at specific times and made clear that a patient may apply at any time without any time limits.
Although HB 1504 did not move forward during legislative session, the issue remains and it could move during the upcoming session. WSHA instead committed to Representative Jinkins that we would work with our members to develop both a standard financial assistance application form and standard plan for communicating and providing notice of the availability of financial assistance. These documents do not dictate the levels of financial assistance offered, but focus on the process used to obtain information related to eligibility. Hospitals may provide different levels of financial assistance; many choose to exceed state and federal requirements.
WSHA Financial Assistance Workgroup
To help with drafting standard forms, in the summer of 2015, WSHA established a workgroup of representatives from seventeen hospitals and health systems. The workgroup has met monthly since August. The workgroup members include the following representatives from large health systems, community hospitals, and small rural hospitals:
- Capital Medical Center
- CHI Franciscan Health
- MultiCare Health System
- Newport Hospital & Health Services
- Olympic Medical Center
- Overlake Medical Center
- PMH Medical Center
- Providence Health & Services
- Seattle Children’s
- Summit Pacific Medical Center
- Toppenish Community Hospital
- UW Medicine/University of Washington Medical Center
- Virginia Mason Medical Center
- Yakima Regional Medical and Cardiac Center
- Yakima Valley Memorial Hospital
Based on prior patient focus groups, the workgroup decided to use the term “financial assistance” to encompass both the state law term of “charity care” and the broader context of hospital financial assistance (which can include assistance with Medicaid applications). The focus groups showed that patients who are eligible for financial assistance do not necessarily think they are poor enough for “charity care.” For both the standard application form and the standard communication plan, the workgroup considered the requirements of Washington State’s charity care law and the recently finalized IRS 501(r) regulations on financial assistance applicable to charitable tax-exempt 501(c)(3) hospitals. Not all Washington State hospitals are subject to federal 501(r) regulations, but the workgroup supported creating standard documents that comply with state and federal law.
Standard Financial Assistance Application Form
The workgroup spent significant time discussing and drafting a standard financial assistance application form. During the conversations, it was evident that hospitals request varying degrees of detail. The workgroup reviewed current application forms used by hospitals and used the best applications to create a draft form and instruction sheet. The workgroup operated under the assumption that the standard application form would serve as a “closed universe” – meaning that individual hospitals may choose to delete questions on the standard form, but no hospital may ask for additional information beyond what is included in the standard form. Because many hospitals exceed legal requirements on levels of income needed to qualify for assistance, the instruction sheet includes a space for each hospital to provide hospital-specific information about income levels at which a patient would qualify for financial assistance.
The workgroup discussed and excluded several items found on many current applications that have concerned patients and advocates, such as bankruptcy and primary homeownership, detailed asset lists, and deadlines for application completion.
Standard Minimum Communication Plan
The workgroup also provided input on a standard communication plan that sets out the minimum steps hospitals should be taking to communicate to patients the availability and eligibility criteria for financial assistance. This includes many communications that hospitals already provide, such as notice on billing statements and public signage. It also includes a recommendation on providing patients with a plain language summary of financial assistance availability, which is a requirement under federal 501(r) regulations.
See the two-page standard communication plan.
Review this bulletin and the linked application and communication plan. Please share comments and feedback with WSHA by December 1, 2015.
The application and communication plan will be reviewed by several WSHA groups in early December and by the WSHA Board. If approved, we would ask all hospitals to change their practices to conform to these processes by October 2016. While the finalized documents may differ somewhat from the linked drafts as hospitals provide input, each hospital and health system should consider how it will operationalize the use of a standard application form and communication plan.
We also ask that hospitals review their levels of charity care to make sure they are in compliance with state law, with IRS requirements if a hospital is a 501(c), and with a pledge that every hospital CEO agreed to in 2007. Additional information on the pledge is on our website. Conformance with the pledge also may assist 501(c)(3) hospitals in meeting certain requirements contained in the IRS 501(r) regulations.
Please do not hesitate to contact WSHA with your questions and comments. Zosia Stanley, Policy Director, can be reached at ZosiaS@wsha.org or 206-216-2511.
Washington State Charity Care Statute, RCW 70.170
Washington State Charity Care Regulations, WAC 246-453
IRS 501(r) Final Treasury Regulation (§§ 1.501(r)-1 to 1.501(r)-7) and commentary (applicable to 501(c)(3) hospitals)
Current Federal Poverty Guidelines, U.S. Department of Health & Human Services