Date: April 26, 2016
To: Hospital Administrators and Chief Executive Officers, Chief Financial Officers, Chief Operations Officers, Chief Nursing Officers, Legal Counsel, Public Policy Advisory Group, Communication Leaders, WSHA Financial Assistance Workgroup, Hospital Lobbyists
From: Zosia Stanley, JD, MHA, Policy Director, Access and Cassie Sauer, Executive Vice President
Staff Contact: Zosia Stanley, Policy Director, Access, (206) 216-2511, firstname.lastname@example.org
Subject: Universal Adoption of Standard Financial Assistance Application and Standard Communication Plan
This bulletin’s purpose is to share the WSHA-developed standard financial assistance/charity care application and standard communication plan for communicating about financial assistance/charity care and recommend that all hospitals adopt both documents.
This recommendation applies to all hospitals in Washington State.
Recommendation: Universal Adoption
The WSHA Board of Trustees unanimously voted to urge every hospital in Washington State to adopt the standard financial assistance/charity care application form and standard communication plan. Adopting the application and communication plan are the right thing to do for our patients, our communities, and our hospitals.
The following documents are available on the WSHA website to assist hospitals:
- Standard Financial Assistance/Charity Care Application and Instruction Sheet
- Guidance on Adoption of Standard Application Form and Instruction Sheet
- Standard Communication Plan for Financial Assistance/Charity Care
- Model Plain Language Summary
WSHA will provide translated versions of the standard language in the application form and instruction sheet, as well as the model plain language summary, for the major languages spoken across the state. The identified languages for translation are: Amharic, Arabic, Cambodian, Chinese, Korean, Lao, Punjabi, Russian, Somali, Spanish, Ukrainian, and Vietnamese. We welcome your feedback on these language selections. For the sections of the application form and instruction sheet that need to be individualized for each hospital or system, we can connect you with our translation vendor. In addition, WSHA will work with hospitals to pool resources to address additional translation needs for languages spoken by low English proficiency groups in a single county or service area.
State law and federal law require hospitals to provide translation for patients in their communities. State law requires hospitals to provide translation on financial assistance for languages spoken by more than ten percent of the population in the hospital’s service area, and interpreted for those who cannot read or understand the information. Federal law requires 501(c)(3) hospitals to provide translation of the hospital’s financial assistance policy, application form, and plain language summary of the financial assistance policy into languages spoken by each low English proficiency language group that constitutes the lesser of 1,000 individuals or five percent of the community served by, or likely to encountered by, the hospital facility.
These documents represent significant work by WSHA and our members to develop the means to make it easier for patients to apply for financial assistance (also known as charity care), while ensuring hospitals and health systems can collect information necessary to evaluate a patient’s eligibility for free or reduced cost care.
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. To address these concerns and to avoid potentially burdensome legislative mandates, WSHA committed to 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. Hospitals and health systems may individualize the application form and instruction sheet as noted in the adoption guidance, but it is important that the instruction sheet and application remain in their standard form. Maintaining the overall look and contents of the documents will help meet the goal of improving the patient experience across facilities.
The standard application and communication plan focus on the patient experience portions of the financial assistance process. They do not dictate the levels of financial assistance offered at individual hospitals. Hospitals may provide different levels of financial assistance; many choose to exceed state and federal requirements. The standard documents are drafted to comply with both state charity care law (applicable to all Washington State hospitals) and federal 501(r) IRS regulations (applicable to federally tax exempt 501(c)(3) hospitals). They also reflect the voluntary pledge made by hospital CEOs in 2007 to provide care at a sliding scale up to 300% of the Federal Poverty Guidelines.
WSHA will host a webinar to further discuss universal adoption of the standard documents on Friday, May 6, 2016, 10:00am to 12:00pm. This is a members-only webinar. Please contact Maria Harwood at (206) 577-1840 or email@example.com to register for the webinar. We will record the session for those who are unable to attend and we strongly encourage attendance.
WSHA will send out a survey to hospital CFOs to follow up on each hospital’s plans for adoption. We will ask for information on your plans, the contact at your hospitals for this work, and what help or support you need from WSHA. Please respond by May 31, 2016.
The deadline for adoption of the application and communication plan is October 31, 2016.
As you adopt the application form and communication plan, please review your policies and procedures and, if necessary, update them to ensure the new form and communication plan fit within your financial assistance/charity care structure. Also, remember to submit any revisions to financial assistance/charity care policies to the Washington State Department of Health, as required by state law. Pursuant to the standard communication plan (and federal 501(r) requirements), also post your updated financial assistance policy on your hospital’s website.
We also ask that hospitals review their levels of charity care to make sure they are in compliance with (1) state law, (2) IRS requirements if a hospital is a 501(c)(3), and (3) the ongoing pledge to provide care at a sliding scale up to 300% of the Federal Poverty Guidelines. Additional information on the pledge is onour website. WSHA represents to legislators that all hospitals continue to honor and follow this pledge. Conformance with the pledge may also assist 501(c)(3) hospitals in meeting certain requirements contained in the IRS 501(r) regulations.
Finally, WSHA encourages members to verify that hospitals are in compliance with transparency and communication obligations, including financial assistance/charity care signage and notices. Both legislators and enforcement entities have expressed interest in making sure hospitals are meeting obligations to clearly and consistently communicate information to patients, staff, and the community. WSHA has compiled a list of state and federal signage and notice requirements, available on our website.
Thank You to WSHA’s Financial Assistance Workgroup
WSHA brought together a workgroup of representatives from seventeen hospitals and health systems to draft the application and communication plan. The workgroup met throughout 2015 and included the following representatives from large health systems, community hospitals, and small rural hospitals:
- Kristie Fiess, Revenue Cycle Director, Capital Medical Center
- Dianna Kielian, Senior Vice President of Mission, CHI Franciscan Health
- Audrey Wheeler, Market Director, Conifer Health Solutions, CHI Franciscan Health
- Richard Gould, Director, Revenue Cycle, EvergreenHealth
- Rena Cardenas, Manager, Patient Financial Experience, MultiCare Health System
- Trina Gleese, Business Services Manager, Newport Hospital & Health Services
- Lisa Morse, Patient Financial Services Manager, Newport Hospital & Health Services
- Barbara Shillington, Financial Services Supervisor, Olympic Medical Center
- Joanna Weber, Director, Revenue Cycle Management, Olympic Medical Center
- Eric Teshima, Controller, Overlake Medical Center
- Peter Frutiger, Director, Revenue Cycle, Overlake Medical Center
- Angela Hillebrand, Program Manager, Revenue Cycle, PeaceHealth
- Bonnie Berg, Manager Patient Financial Services, PMH Medical Center
- Lesa Ellis, Director, Financial Counseling & Assistance, Providence Health & Services
- Kelly Kikuchi, WA/MT Manager ,Financial Counseling, Providence Health & Services
- Karen Koop, Director, Revenue Cycle Process Improvement, Seattle Children’s
- Shauna DePrato, Finance Director, Summit Pacific Medical Center
- Cindy Ríos, Market Chief Financial Officer, Toppenish Community Hospital and Yakima Regional Medical and Cardiac Center
- Jo MacKay, Manager, Revenue Operations, Virginia Mason Medical Center
- Jane Blackwell-Schuyler, Director of Patient Access, Hospital Operations, University of Washington Medical Center and University of Washington Harborview Medical Center
- Matt Lund, Director of Contracting, UW Medicine
- Tim Reed, Chief Financial Officer, Yakima Valley Memorial Hospital
- Jamon Rivera, Senior Director, Revenue Operations, Yakima Valley Memorial Hospital
A sincere thank you to this group for their work and kudos on the excellent finished products.