PURPOSE:

As part of our mission, Rothman Orthopaedic Specialty Hospital, L.L.C. (“ROSH”) strives to be an innovative specialty hospital dedicated to the needs of the community we serve. As a musculoskeletal facility, we strive to deliver efficient, high quality, cost-effective healthcare services. ROSH is committed to treating patients with dignity and consideration, regardless of their financial circumstances.

This Financial Assistance Policy (“FAP”) will outline ROSH’s financial assistance policies, practices and procedures. This policy shall include all necessary information in compliance with Internal Revenue Code (“IRC”) Section §501(r), as well as applicable federal, state and local law.

POLICY:

In accordance with this FAP, ROSH is committed to providing financial assistance for medically necessary healthcare services, to patients who are uninsured, underinsured, ineligible for government assistance or are otherwise unable to pay for services based on their individual financial situation.

ROSH considers each patient’s ability to pay for his or her emergency or medically necessary healthcare services and offers financial assistance to patients residing in its primary service area, who meet the eligibility criteria described herein. ROSH also, in limited circumstances provides financial assistance to those who qualify for Medical Indigence standards as set forth in this policy.

ROSH is a specialty hospital facility and does not have a dedicated emergency department, nor does it have specialized capabilities that would make it appropriate to accept transfers of individuals who need stabilizing treatment for an emergency medical condition. However, ROSH has established a written emergency medical care policy that addresses how it appraises emergencies, provides initial treatment, and refers or transfers an individual to another facility, when appropriate, in a manner that complies with the Federal Emergency Medical Treatment and Labor Act (“EMTALA”) regulations. Additionally, patients seeking emergency care at ROSH are not subject to financial screening prior to receiving care. Patients will not be subject to debt collection activities that would interfere with emergency medical care. The granting of financial assistance will not take into account age, gender, race, social or immigration status, sexual orientation, or religious affiliation. ROSH shall operate in accordance with all federal, state, and local requirements for the provision of health services, including screening and transfer requirements under EMTALA.

Please note, not all medically necessary healthcare services provided within ROSH’s hospital facility are provided by ROSH employees, and therefore, may not be covered under this FAP. Please refer to Appendix A for a list of contracted providers that provide medically necessary healthcare services within the hospital facility. This appendix specifies which providers are covered under this FAP and which are not. The provider listing will be reviewed quarterly and updated, if necessary.

DEFINITIONS:

For the purpose of this FAP, the terms below are defined as follows:

Amounts Generally Billed (“AGB”): Pursuant to IRC §501(r)(5), in the case of emergency or other medically necessary care, FAP-eligible patients will not be charged more than an individual who has insurance covering such care.

AGB Percentage: A percentage of gross charges that a hospital facility uses to determine the AGB for any emergency or other medically necessary care it provides to an individual who is eligible for assistance under the FAP.

Application Period: The time period during which an individual may apply for financial assistance. In accordance with IRC §501(r)(6), an individual is allowed up to 240 days from the date the individual is provided with the first post-discharge billing statement to apply for financial assistance.

Eligibility Criteria: The criteria set forth in this FAP (and supported by procedure) used to determine whether a patient qualifies for financial assistance.

Extraordinary Collection Actions:

1. Reporting adverse information to consumer credit reporting agencies or credit bureaus.
2. Deferring or denying, or requiring payment before providing medically necessary healthcare services because of an individual’s nonpayment of one or more bills for previously provided care covered under this policy.
3. Actions that require a legal or judicial process, including but not limited to:

1. • Placing a lien on a property;
   • Attaching or seizing an individual’s bank account or any other personal property;
   • Commencing a civil action;
   • Causing an individual to be subject to a writ of body attachment;
   • Wage garnishment.

Financial Assistance: In accordance with this FAP, financial assistance provides a patient with free or discounted emergency or other medically necessary healthcare services if they meet the established criteria and are determined to be eligible.

FAP-eligible: Individuals who are eligible for full or partial financial assistance under this policy.

Federal Poverty Guidelines (“FPG”): A measure of income level issued annually by the Department of Health and Human Services. ROSH uses FPG are used to determine eligibility for financial assistance.

Gross Charges: The hospital facility’s full, established price for medical care that is consistently and uniformly charged to patients before applying any contractual allowances, discounts or deductions.

Medically Necessary Care: A service, item, procedure or level of care that is necessary for the proper treatment or management of an illness, injury or disability is one that:

1. Will, or is reasonably expected to, prevent the onset of an illness, condition, injury or disability.
2. Will, or is reasonably expected to, reduce or ameliorate the physical, mental or developmental effects of an illness, condition, injury or disability.
3. Will assist the recipient to achieve or maintain maximum functional capacity in performing daily activities, taking into account both the functional capacity of the recipient and those functional capacities that are appropriate of recipients of the same age.

Notification Period: 120-day period, which begins on the date of the 1st post-discharge billing statement, in which no ECAs may be initiated against the patient.

Plain Language Summary (“PLS”): A written statement which notifies an individual that ROSH offers financial assistance under this FAP and provides additional information in a clear, concise and easy to understand manner.

Primary Service Area: The areas proximate to the hospital facility where more than half of its patients reside. In accordance with ROSH’s most recently conducted Community Health Needs Assessment, this includes communities in Bucks, Montgomery and Philadelphia counties that are aggregated into 6 geographically contiguous regions defined by zip-codes.

Under-insured: The patient has some level of insurance or third-party assistance but still has out-of-pocket expenses that exceed their financial abilities.

Uninsured: The patient has no level of insurance or third-party assistance to assist with meeting their payment obligations.

FINANCIAL ASSISTANCE ELIGIBILITY CRITERIA:

Patients whose income does not exceed 200% of FPG are eligible for 100% financial assistance coverage. The FPG are issued annually in the Federal Register by the Department of Health and Human Services. The most recently issued FPG can be found at the following website: https://aspe.hhs.gov/poverty-guidelines

Each patient applying for financial assistance must make a good faith effort, as determined by the hospital facility, to obtain coverage from available public assistance programs such as:

1. 1. Medicare
   2. Medicaid
   3. Vocational rehabilitation
   4. Victims of Crime
   5. Children Special Services
   6. Church program

A patient who refuses to apply or follow through with applications for other assistance will not be eligible for financial assistance.

BASIS FOR CALCULATING AMOUNTS CHARGED TO PATIENTS:

In accordance with IRC §501(r)(5) ROSH utilizes the Look-Back Method to calculate the AGB. The ABG % is calculated annually and is calculated by dividing the sum of the amount of all its claims for emergency or other medically necessary care that have been allowed by Medicare over a 12-month period, by the gross charges associated with those claims. The applicable AGB % is applied to gross charges to determine the AGB.

The calculated AGB percentage, as well as an accompanying description of the calculation, is available upon request and free of charge by calling the Billing Office at (215) 244-7481.

Any individual determined to be eligible for financial assistance under this FAP will not be charged more than the AGB for medically necessary healthcare services. Any FAP-eligible individual will always be charged the lesser of AGB or any discount available under this policy.

Please note, in accordance with this policy, individuals who are deemed FAP-eligible will receive full financial assistance from the hospital facility. Therefore, the discount offered under this policy will exceed the AGB for FAP-eligible individuals. However, in accordance with IRC §501(r) ROSH performs an ABG calculation, on an annual basis, to ensure the hospital facility is in full compliance with these regulations.

PROCEDURES:

Applying for Financial Assistance

In order to be considered for financial assistance, patients who believe they are eligible must complete a Financial Assistance Application Form (“Application”) and attach all applicable supporting documentation.

Income verification will be required by one or more of the following: pay stubs, W-2 forms, tax returns, an employer written statement, and any other relevant documentation.  Other documentation required includes, but is not limited to, copies of the following:

1. • Medical bills
   • Utility bills
   • Car payment stubs
   • Rent receipts
   • Bank statements
   • Alimony/child support receipts
   • Government assistance receipts
   • Other income/investment statements (e.g. 401K)

Obtaining an Application:

Patients who wish to apply for the financial assistance offered under this FAP can obtain an Application on our website: http://rothmanorthohospital.com/for-patients/financial-assistance/

Applications may be requested by calling the Billing Office at (215) 244-7481.

Paper copies of the Application are also available, free of charge, at the Registration Desk of Rothman Orthopaedic Specialty Hospital located at:

Rothman Orthopaedic Specialty Hospital

Registration Desk

3300 Tillman Drive

Bensalem, PA 19020

All completed Applications may be dropped off or mailed to:

Rothman Orthopaedic Specialty Hospital

Attn: Billing Office

3300 Tillman Drive

Rothman Orthopaedic Specialty Hospital

Application Process

Business Office associates (“associate”) are available to help patients with their Applications. Applications may either be completed in-person with an associate or completed individually and submitted to an associate for review and processing. In person assistance is available at the Registration Desk Monday through Friday from 8 am to 4 pm.

If you need information about the FAP, or need help in completing this application please contact the Billing Office by phone at (215) 244-7481 or visit the Registration Desk of Rothman Orthopaedic Specialty Hospital located at 3300 Tillman Drive, Bensalem, PA 19020.

Approval Process

Prior to being screened for financial assistance, applicants must be screened to determine their potential eligibility for any third-party insurance benefits or medical assistance programs that may pay towards the hospital bill. Patients will not be deemed eligible for financial assistance under this FAP until they are determined to be ineligible for any other medical assistance programs (i.e. Medicaid, Medicare, etc.)

Process for Incomplete Applications:

If an Application for financial assistance is incomplete and an immediate determination of FAP-eligibility cannot be made, ROSH will notify the patient and request additional information from the applicant within 30 days. ROSH will provide the applicant with a written notice which describes the additional information/documentation needed to make a FAP-eligibility determination. The patient will have an additional 30 days to supply the information/documentation requested. During this time ROSH, or any third parties acting on their behalf, will suspend any ECA’s previously taken to obtain payment until a FAP-eligibility determination is made.

Process for Completed Applications

Once a completed Application is received, ROSH will:

• Suspend any ECAs against the individual (any third-parties acting on ROSH’s behalf will also suspend ECAs undertaken);
• Make and document a FAP-eligibility determination in a timely manner; and
• Notify the responsible party or individual in writing of the determination and basis for determination.

An individual deemed eligible for financial assistance will be notified in writing of a favorable determination. In accordance with IRC §501(r) ROSH will also

• Provide a billing statement indicating the amount the FAP-eligible individual owes, how that amount was determined and how information pertaining to AGB may be obtained, if applicable;
• Refund any excess payments made by the individual; and
• Work with third parties acting on ROSH’s behalf to take all reasonable available measures to reverse any ECAs previously taken against the patient to collect the debt.

The Vice President of Finance must approve all applications for financial assistance and medical indigence. Patients will be notified in writing once ROSH makes a financial assistance determination. A FAP-eligibility determination shall be made within 30 days of receipt of the patients completed FAP Application.

Please note, the approval of an Application will not be considered as an approval for any or all future accounts. Each application will require new verification information to be considered for financial assistance.

The completed Application, including any applicable supporting documentation, should be returned to the Business Office for account reconciliation and the appropriate write-off applied to the account prior to closing the accounting month.  Write-offs should be performed using the appropriate financial assistance write-off code.

If a patient does not qualify for medical assistance through the state or financial assistance in accordance with this FAP, please refer to FINBO.06 – Discounts for Self Pays, Uninsured and Non-Contracted Payers.

ROSH reserves the right to reverse financial assistance approval, if the information provided by the patient in their Application is later determined to be falsified or is compensation for services obtained from another source.

DISSEMINATION OF FINANCIAL ASSISTANCE DOCUMENTS & WIDELY PUBLICIZING THE AVAILABILITY OF FINANCIAL ASSISTANCE:

The FAP, Application and PLS are all available on-line at the following website: http://rothmanorthohospital.com/for-patients/financial-assistance/

Paper copies of the FAP, Application and the PLS are available upon request without charge by mail and are available at the Registration Desks and within the Billing Office located at 3300 Tillman Drive Bensalem, PA 19020.

All patients of ROSH will be offered a copy of the PLS as part of the intake process.

Signs or displays informing patients about the availability of financial assistance will be conspicuously posted in public locations including patient registration check-in areas.

ROSH will make reasonable efforts to inform members of the community about the availability of financial assistance.

ROSH’s FAP, Application and PLS are available in English and in the primary language of populations with limited proficiency in English (“LEP”) that constitute the lesser of 1,000 individuals or 5% of the community served within the organization’s primary service area.

Additionally, billing statements will include information about the availability of financial assistance, as well as contact information for individuals who believe they may qualify.

BILLING & COLLECTION POLICY

PURPOSE:

To establish standards to ensure systematic, consistent and timely collection follow-up.

SCOPE:

All accounts with outstanding balances that do not have appropriate payment arrangements.

PROCEDURE:

Once a patient’s claim is processed by their insurance, ROSH will send the patient a bill indicating the patient responsibility. Additionally, if a patient has no third-party coverage they will receive a bill indicating their patient responsibility. This will be the patients first post discharge billing statement. The date on this statement will begin the Application and Notification Periods (defined above).

Patient statements will be generated daily following payment posting or weekly at a minimum. Preferences have been pre-determined in the patient accounting system to ensure that patient statements are generated on a cycle basis and that patient responsible accounts will have a statement generated monthly. After the patient receives their first post discharge billing statement, ROSH will send out 2 additional statements (in 30-day intervals).

The Business Office Manager or designee shall follow up on returned statements for incorrect or invalid address by contacting the patient or guarantor on the account.

The Business Office Manager/staff will make follow-up phone calls on every account with outstanding balances.

Insurance Due Accounts should have the initial follow-up call made 30 days following the date of service.  Subsequent follow-up calls should be made every 14 days until the balance is paid.  Insurance Due balances over 90 days old for which the facility has not received valid reasons from the payer as to why the charges have not been paid may be transferred to patient due status and billed to the patient at the discretion of the Administrator or Business Office Manager.

Patient Due Accounts should have the initial follow-up call made 21 days following the date of service for self-pay accounts and following the date the amount was transferred to the patient’s obligation if the amount was initially billed to a primary insurance. Subsequent follow-up calls should be made every 14 – 21 days until the balance is paid or until adequate payment arrangements are made.

If payment has not been received after 90 days (from the date of the patients first post-discharge billing statement) ROSH will send out a letter informing the patient in writing that the account will be sent to collections, if payment is not received within 30 days of the date of the letter. The Business Office Manager or designee shall ensure that patient responsible accounts have a minimum of three (3) statements generated to the patient prior to the account being written off or considered for collection agency placement. Additionally, the letter will include any ECAs (defined above) that may take place after the patient account has been placed in collections. The written notice will also include a copy of the PLS.

All Outstanding Accounts (insurance balances and patient balances) aged 120 days without appropriate payment arrangements or may be outsourced to an outside agency or considered for write off to bad debt and sent to a collection agency in accordance with the Bad Debt Write-off Policy (FINBO.35). The following information should be included with the accounts when outsourced or sent to the collection agency:

1. 1. Print screen of all collection memos
   2. Print screens of patient demographics, billing data, insurance verification authorization information, statement dates, etc.

Documentation

An Aged Trial Balance with patient balances will be printed every other week and every outstanding account should be worked.

Collector’s Desktop will be worked daily to ensure that all account follow up is current.

All notes regarding written and/or verbal communication on the account will be maintained in the “comment” file on the patient’s account and should include the following:

1. 1. Date of collection work
   2. Time of collection work
   3. Telephone # of contact
   4. Full name of contact
   5. Location of contact (home, work, employer, insurance co.)
   6. Complete summary of conversation
   7. Next follow-up date based on payment promises

Compliance with IRC §501(r)(6)

In accordance with IRC §501(r)(6), ROSH does not engage in any ECAs prior to the expiration of the Notification Period. Subsequent to the Notification Period ROSH, or any third parties acting on its behalf, may initiate the following ECAs against a patient for an unpaid balance if a FAP-eligibility determination has not been made or if an individual is ineligible for financial assistance.

1. • Reporting adverse information about the individual to consumer credit reporting agencies or credit bureaus; and
   • Placing a lien on an individual’s property.

ROSH may authorize third parties to initiate the ECAs included above on delinquent patient accounts after the Notification Period. ROSH, and third parties acting on its behalf, do not engage in any other ECA’s defined within IRC §501(r)(6).

ROSH will ensure reasonable efforts have been taken to determine whether or not an individual is eligible for financial assistance under this FAP and will take the following actions at least 30 days prior to initiating any ECA:

1. 1. The patient will be provided with written notice which:
      • Indicates that financial assistance is available for eligible patients;
      • Identifies the ECA(s) that ROSH intends to initiate to obtain payment for the care; and
      • States a deadline after which such ECAs may be initiated.
   2. The patient has received a copy of the PLS with this written notification; and
   3. Reasonable efforts have been made to orally notify the individual about the FAP and how the individual may obtain assistance with the financial assistance Application process.

ROSH, and third-party vendors acting on their behalf, will accept and process all Applications for financial assistance available under this policy submitted during the Application Period.

ROSH will not pursue any collection actions against anyone eligible for financial assistance under this policy, and will not pursue Extraordinary Collection Actions against any individual without first making reasonable efforts to determine if the patient is eligible for financial assistance. The Vice President of Finance will determine if reasonable efforts have been made. 

Appendix A:

Rothman Orthopaedic Specialty Hospital Provider Listing

Contracted physicians and certain other healthcare providers delivering services within Rothman Orthopaedic Specialty Hospital are not otherwise required to follow this Financial Assistance Policy.

The following is a list of providers, by specialty, that provide medically necessary healthcare services within the hospital facility.

List of Providers who are not covered under this Financial Assistance Policy:

• Anesthesiology
• Cardiology
• Infectious Disease
• Internal Medicine
• Pain Medicine
• Pathology
• Physical Medicine/Rehabilitation
• Podiatry
• Radiation Oncology
• Sports Medicine
• Surgeons (Orthopaedic, Neurological, Vascular)
• Urology

There are currently no contracted physicians/providers delivering services within the hospital facility that are covered under this FAP.