CREDIT AND COLLECTION POLICY

Milford Regional Medical Center, Inc. (MRMC) is committed to providing you with high-quality care and services.  As part of this commitment Milford Regional Medical Center, Inc. works with individuals with limited incomes and resources to find coverage for their care.  Our financial assistance program helps low-income, uninsured and underinsured individuals determine if they are eligible for public assistance or through other sources, including Milford Regional Medicals Center’s financial program.

Financial assistance is available from the hospital for uninsured and underinsured individuals who cannot get public assistance and cannot afford to pay for their medical care.  The premise of the program is that all individuals are expected to contribute to their care, based on their ability to pay.  Assistance is given based on the individuals’ household income, assets, family size, expenses and medical needs.  We understand that each individual has a unique financial situation and encourage you to contact our certified application counselors for more information.  They can be reached at 508-473-1190, Ext. 8 between 8:00 AM – 4:50 PM, Monday through Friday.

Each request for assistance is handled confidentially and requires the cooperation of the applicant.  MRMC does not discriminate on the basis of race, color, national origin, citizenship, alienage, religion, creed, sex, sexual orientation, gender identity, age or disability in its policies or in its application of policies, concerning the acquisition and verification of financial information, pre-admission or pre-treatment deposits, payment plans, deferred or rejected admissions, low income patient status, in its billing and collection practices 613.08(1) (a).

This policy was developed to ensure compliance with the Massachusetts Health Safety Net Eligible Services Regulation (101 CMR 613.000) and generally meets the IRS regulations (Internal Revenue Code Section 501(r)) which are effective for hospitals starting in December of 2016. 

I.   Delivery of Healthcare Services as it Applies to Financial Assistance

Milford Regional Medical Center, Inc. will provide, without exception, care for emergency medical conditions to all individuals seeking such care, regardless of their ability to pay for or to qualify for financial assistance, in accordance with the requirements of the Federal Emergency Medical Treatment and Labor Act (EMTALA).  Financial assistance is available for an individual who is seeking emergent, urgent or medically necessary care.  The hospitals’ financial assistance program may not apply to certain elective procedures or elective procedures or services that are covered by a third party, (Such as a private insurance or a public assistance program).

It is important to note that classification of individuals’ medical conditions is for clinical management purposes only, and such classifications are intended for addressing the order in which physicians should see individuals based on their presenting clinical symptoms.  These classifications do not impact the order in which an individual is provided financial assistance.  For those individuals that are uninsured or under insured, the hospital will work with individual to assist with finding a financial assistance program that may cover some or all of their unpaid hospital bill(s).  For those individuals with private insurance, the hospital must work through the individual and the insurer to determine what may be covered under the individual’s insurance policy.  As the hospital is often not able to get this information from the insurer in a timely manner, it is the individual’s obligation to know what services will be covered prior to seeking elective or scheduled services.  For purposes of this policy, the following services are differentiated in the following manner for determining the medical care needed and what may be covered by a specific public or private coverage option for consideration of a patient’s allowable bad debt:

A.  Emergency Level Services

Includes medically necessary services provided after the onset of a medical condition, whether physical or mental, manifesting itself by symptoms of sufficient severity including severe pain, that the absence of prompt medical attention could reasonably be expected by a prudent layperson who possesses an average knowledge of health and medicine to result in placing the health of the person or another person in serious jeopardy, serious impairment to body function or serious dysfunction of any body organ or part or, with respect to a pregnant woman, as further defined in section 1867 (e)(1)(B) of the Social Security Act, 42 U.S.C. § 1295dd(e)(1)(B).  A medical screening examination and any subsequent treatment for an existing emergency medical condition or any other such service rendered to the extent required pursuant to the federal EMTALA 42 U.S.C. 1395(dd) qualifies as an Emergency Level Service.

B.  Urgent Care Services

Includes medically necessary services provided in an Acute Hospital or Community Health Center after the sudden onset of a medical condition, whether physical or mental, manifesting itself by acute symptoms of sufficient severity (including severe pain) that a prudent layperson would believe that the absence of medical attention within 24 hours could reasonably expect to result in placing a patient’s health in jeopardy, impairment to bodily function or dysfunction of any bodily organ or part.  Urgent Care Services are provided for conditions that are not life threatening and do not pose a high risk of serious damage to an individual’s health.  Urgent Care Services do not include Primary and Elective Care.

C.  Primary or Elective or Scheduled Services

Are provided to individuals who either:

1.   Arrive to the hospital seeking non-emergent or non-urgent level care or

2.   Seek additional care following stabilization of an emergency medical condition. 

Elective or scheduled services are either primary care services or medical procedures scheduled in advance by the individual or by the health care provider (hospital, physician office, other).

II.  Documentation Eligibility for Enrollment in Massachusetts Public Assistance Programs

A.  General Principles

Financial assistance is intended to assist low-income individuals who do not otherwise have the ability to pay for their health care services.  Such assistance takes into account each individual’s ability to contribute to the cost of his or her care.  For those individuals that are uninsured or underinsured, the hospital will, when requested, help them with applying for available financial assistance programs that may cover all or some of their unpaid hospital bills.  The Hospital provides this assistance for both residents and non–residents of Massachusetts; however, there may not be coverage through a Massachusetts public assistance program for an out-of-state resident.  In order for the hospital to assist uninsured and underinsured individuals find the most appropriate coverage options as well as determine if the individual is financially eligible for any discounts in payments, individuals must actively work with hospitals to verify their documented family income, other insurance coverage and any other information that could be used in determining eligibility.

B.  Enrollment in a Public Assistance Program

Hospitals have no role in specifically determining the eligibility for enrollment within a public assistance program.  In Massachusetts, individuals that apply for coverage with MassHealth, the premium assistance payment program offered through the Health Connector (including Connector Care), Health Safety Net, the Children’s Medical Security Program, or Medical Hardship must do so through a single uniform application that is submitted through the state’s new enrollment system called the Health Insurance Exchange, (HIX).  Through this process, the individual can submit an application through an online website (which is centrally located on the state’s Health Connector Website), a paper application, or over the phone with a customer service representative located at either MassHealth or the Connector.  Individuals may also ask for assistance from the hospital’s certified application counselor with submitting the application either on the website or through a paper application.

In order to apply for coverage, the following process occurs:

1.   An individual is requested to develop an online account for use by the state to conduct an identity verification of the individual.  Once this is completed, the individual is then able to submit a completed application through the hCentive system on the connector website.  If the individual does not want to go through the online identity verification system, they can submit a paper application.  Other verification may still be needed, including proof of income, residency and citizenship.

2.   Once the application is received, the state will verify the eligibility by comparing the individuals’ financial and other demographic information to a federal data site as well as conducting an income review using a modified adjusted gross income review.  If necessary, the individual will also submit additional verification as requested by the system.  Once this occurs, the individual is deemed:

a.     Eligible for MassHealth coverage, upon which the individual is notified by mail from MassHealth, which includes eligibility information including start date and other pertinent information; or

b.     If the individual is eligible for a qualified health plan through the Health Connector Program, they are notified of their eligibility and directed to take additional steps.  This includes:

• Choosing a Plan;
• Paying their monthly premium; or
• Enrolling and receiving their proof of coverage.

More information regarding the MassHealth and Connector program benefits and application process can be found at www.mass.gov/masshealth and www.mahealthconnector.org.

III. Assisting Individuals Seeking Coverage Through a Massachusetts Public Assistance Program

A.  General Principles

For those individuals who are uninsured or underinsured, the hospital will work with them to assist with applying for available financial assistance programs that may cover some or all of their unpaid hospital bills.  In order to help uninsured and underinsured individuals find available and appropriate financial assistance programs, the hospital will provide all individuals with a general notice of the availability of programs in both the bills that are sent to individuals, as well as in general notices that are posted throughout the hospital.  The goal of these notices is to assist individuals in applying for coverage within a public assistance program, including MassHealth, premium assistance payment programs offered through the Health Connector, (including Connector Care), Health Safety Net, the Children’s Medical Security Program and Medical Hardship. 

B.  Role of Hospital Certified Application Counselor

The hospital provides individuals with information about financial assistance programs that are available through the Commonwealth of Massachusetts.  By contracting with the Executive Office of Health and Human Services (MassHealth) and the Commonwealth Health Insurance Connector Authority (Connector) the hospital has been deemed a Certified Application Counselor Organization.  Through this authority, the hospital works with its staff, contractors and volunteers to be trained in the eligibility and benefit rules and regulations and be certified as a MassHealth, premium payment program offered by the Health Connector (including Connector Care), Health Safety Net, the Children’s Medical Security Program and Medical Hardship.

As a Certified Application Counselor (CAC), the hospital staff will inform the individual of the functions and responsibility of a CAC, seek that the individual sign a Certified Application Counselor Designation Form, and assist the individual in finding applicable public assistance by:

• providing information about the full range of programs, including MassHealth, premium assistance payment program offered by the Health Connector (including Connector Care), Health Safety Net, the Children’s Medical Security Program and Medical Hardship;
• helping individuals complete an application or renewal;
• working with the individual to provide required documentation;
• submitting applications and renewals to the specific programs;
• interacting, when applicable and as allowed under the current system limitations, with the Programs on the status of such applications and renewals;
• helping to facilitate enrollment of applicants or beneficiaries in insurance programs; and
• offer and provide voter registration assistance

It is the individual’s obligation to provide the hospital with accurate and timely information regarding their full name, address, telephone number, date of birth, social security number (if available), current insurance coverage options (including motor vehicle liability insurance) that can cover the cost of the care received, and other applicable financial resources, and citizenship and residency information.  This information will be submitted to the state as part of the application for public programs to determine coverage for the services provided to the individual.

If there is no specific coverage for the services provided, the hospital will work with the patient to determine if a different state program option, such as Medical Hardship would be available following the Health Safety Net regulations.  Such efforts also include working with individuals, when requested by the individual, to determine if a bill for services should be sent to the individual to assist with meeting the One-time Deductible.

 If the individual or guarantor is unable to provide the necessary information, the hospital may (at the individual’s request) make reasonable efforts to obtain any additional information from other sources.  This will occur when the individual is scheduling their services, during pre-registration, while the individual is admitted in the hospital, upon discharge, or for a reasonable time following discharge from the hospital.  Information that the hospital obtains will be maintained in accordance with applicable federal and state privacy and security laws.

The hospital will also conduct reasonable efforts to investigate whether a third party resource may be responsible for the services provided by the hospital, including but not limited to:

• a motor vehicle or home owner’s liability policy;
• general accident policies;
• worker’s compensation programs; and
• student insurance policies, among others. 

In accordance with applicable state regulations or the insurance contract, for any claim where the hospital’s reasonable efforts resulted in a payment from such sources listed above, the hospital works with each individual to notify them of their responsibility to report the payment and offset it against any claim made to MassHealth, the Health Safety Net, or other applicable programs.

C.   Notification Practices

The hospital will post a notice (signs) of availability of financial assistance as outlined in this credit and collection policy in the following locations:

• Service Delivery Areas (e.g., Inpatient, Emergency and Outpatient

      Areas);

• Certified Application Counselor offices;
• Admission/Registration areas; and/or
• Financial offices that are open to individuals.

Posted signs will be clearly visible and legible to individuals visiting these areas.  The wording will state “Having trouble paying medical bills?  If you require assistance in applying for state funded insurance programs please call 508-422-2234”.  Signs are 9x6 inches in size.  The hospital will also include a notice about the availability of financial assistance in all initial bills.

When the individual contacts the hospital, the hospital CACs will attempt to identify if an individual qualifies for a public assistance program or the hospital financial assistance program.  An individual who is enrolled in a public assistance program may qualify for certain benefits.  Individuals may also qualify for additional assistance based on the hospital’s financial assistance program based on the individual’s documented income and allowable medical expenses.

IV.   Hospital Collection Practices

MRMC, INC has a fiduciary duty to seek reimbursement for services it has provided from individuals who are able to pay, from third party insurers who cover the cost of care, and from other programs of assistance for which the patient is eligible.  To determine whether a patient is able to pay for the services provided, as well as to assist the patient in finding alternative coverage options if they are uninsured or underinsured, the Hospital follows the following criteria related to billing and collecting from patients 101 CMR 613.03(1)(c)3.

A.  Collecting Information on Patient Health Coverage and Financial Resources

(1)  Patient Rights and Responsiblities:

Prior to the delivery of any health care services (except for cases that are an emergency or urgent care service level), the patient is expected to provide timely and accurate information on their insurance status, and information on any deductibles or co-payment  that are owed based on their existing insurance or financial program’s payment obligations 613.08(2).  The detailed information will include:

a.     Full name, address, telephone number, date of  birth, social security number (if available), current health insurance coverage options, citizenship and residency information, and the patient’s applicable financial resources that may be used to pay their bill;

b.     Full name of the patient’s guarantor, their address, telephone number, date of birth, social security number (if applicable), current health insurance coverage options and their applicable financial resources that may be used to pay for the patient’s bill; and

c.     Other resources that may be used to pay their bill, including other insurance programs, motor vehicle or homeowners insurance policies if the treatment was due to an accident, worker’s compensation programs, and student insurance policies, among others.

It is ultimately the patient’s obligation to keep track of and timely pay their unpaid hospital bill, including any existing co-payments and deductibles.  The patient is further required to inform either their current health insurer (if they have one), or the agency that determined the patient’s eligibility status in a public health insurance program of any changes in family income or insurance status.  The hospital may also assist the patient with updating their eligibility in a public program when there are any changes in family income or insurance status, but only if the hospital is made aware by the patient of facts that may indicate a change in the patient’s eligibility status.

Patients are required to notify the applicable public program in which they are enrolled (e.g., Office of Medicaid and the Health Safety Net), of any information related to a change in family income and any lawsuit or insurance claim that may cover the costs of the services paid by the applicable public program, such as the Office of Medicaid and the Health Safety Net (notifying them in 10 days of filing any claim, civil action, or any other proceeding). 

(2)  Hospital Rights and Responsibilites

MRMC will make all reasonable and diligent efforts to collect the patient’s insurance status and other information to verify coverage for the health care services to be provided by the Hospital.  For many patients coverage determination is made by either asking for a copy of the patient’s insurance card or checking the Massachusetts Recipient Eligibility Verification System (REVS) for coverage under an applicable public program.  All information will be obtained prior to the delivery of any non-emergent and non-urgent health care services (i.e., elective procedures as defined in this credit and collection policy).  MRMC will delay any attempt to obtain this information during the delivery of any EMTALA level emergency level or urgent care services, if the process to obtain this information will delay or interfere with either the medical screening examination or the services undertaken to stabilize an emergency medical condition.

The Hospital shall advise patients of the responsibilities described in 101 CMR 613.08(2) (b) in all case where the patient interacts with registration personnel.

If the patient or guarantor/guardian is unable to provide the information needed, and the patient consents, the Hospital will make reasonable efforts to contact relatives, friends, guarantee/guardian, and the third party for additional information.  This may occur when the patient is scheduling their services, during pre-registration, while the patient is admitted in the Hospital, upon discharge, or for a reasonable time following discharge from the Hospital.

The Hospital’s due diligence efforts will include, but are not limited to, requesting information about the patient’s insurance status, checking any available public or private insurance databases, following the bill and authorization rules and as appropriate appealing any denied claim when the service is payable in whole or in part by known third party insurance company that may be responsible for the cost of the patients recent healthcare services.  When hospital registration or admission staff are informed by the patient, they shall also work with the patient to ensure that relevant information is communicated to the appropriate public programs.

• a motor vehicle or home owner’s liability policy;
• general accident policies;
• worker’s compensation programs; and
• student insurance policies, among others. 

In accordance with applicable state regulations or insurance contracts, for any claims where the Hospital’s reasonable and diligent efforts resulted in a payment and offset it against any claim that may have been paid by the private insurer or public program.  For state public assistance programs, the Hospital is not required to secure assignment on a patient’s right to a third party coverage on services provided due to an accident.  In these cases the State of Massachusetts will attempt to seek assignment on the costs of the services provided to the patient and which was paid for by either the Office of Medicaid or the Health Safety Net.

The Hospital maintains all information in accordance with the applicable federal and state privacy and security, and ID theft laws.

B.  Hospital Billing and Collection Procedures

MRMC makes the same reasonable effort and follows the same reasonable process for collecting on bills owed by an uninsured patient as it does for all other patients.  The Hospital will first show that it has a current unpaid balance that is related to services provided to the patient and not covered by a private insurer or a financial assistance program. 

The Hospital follows reasonable collection/billing procedures, which include: 

(1)   An initial bill sent to the patient or the party responsible for the patient’s personal financial obligations, the initial bill will include information about the availability of a financial assistance program that might be able to cover the cost of the Hospital’s bill;

(2)   Subsequent billings, telephone call, collection letters, personal contact notices, computer notifications, or any other notification method that constitutes a genuine effort to contact the party responsible for the obligation;

(3)   If possible, documentation of alternative efforts to locate the party responsible for the obligation or the correct address on billings returned by the postal service such as “incorrect address” or undeliverable”;

(4)   Sending a final notice by certified mail for uninsured patients (those who are not enrolled in a public program such the Health Safety Net or MassHealth) who incur an emergency bad debt balance of $1,000 on Emergency Level Services only, where notices have not been returned as “incorrect address” or “undeliverable”; and also notifying the patients of the availability of financial assistance in the communication;

(5)   Documentation of continuous billing or collection action undertaken on a regular, frequent basis is maintained.  Such documentation is maintained until audit review by a federal and/or state agency of the fiscal year cost report in which the bill or account is reported.  The federal Medicare Program and the state division of Health Care Finance and Policy for purposes of the Health Safety Net Program, deems 120 days as appropriate for continuous billing or collection actions.

(6)   Checking the Massachusetts Eligibility Verification System (EVS) to ensure that the patient is not a Low Income Patient as determined and has not submitted an application for coverage for either MassHealth, the premium assistance payment program operated by the Health Connector, the Children’s Medical Security Program, Health Safety Net, or Medical Hardship, to prior to submitting claims to the Health Safety Net Office for emergency bad debt coverage of an emergency level or urgent care service.

C.  Hospital Financial Assistance Programs

Patients who are eligible for enrollment in a state public assistance program, like the Massachusetts MassHealth or Health Safety Net programs, are deemed enrolled in a financial assistance program.  For all patients that are enrolled in these state public assistance programs, the hospital may only bill those patients for the specific co-payment, co-insurance, or deductible that is outlined in the applicable state regulations and which may further be indicated on the state Medicaid Management Information System.

The Hospital will seek a specified payment for those patients that do not qualify for enrollment in a Massachusetts state public assistance program, such as out-of-state residents, but who may otherwise meet the general financial eligibility categories of a state public assistance program.  For these patients, the hospital will notify the patient if such additional resources are available based on the hospital’s financial assistance policy.

The Hospital, when requested by the patient and based on an internal review of each patient’s financial status, may offer a patient an additional discount on an unpaid bill.  Any such review shall be part of a separate hospital financial assistance program that is applied on a uniform basis to patients, and which takes into consideration the patient’s documented financial situation and the patient’s inability to make a payment after reasonable collection actions.  Any discount that is provided by the hospital is consistent with federal and state requirements, and does not influence a patient to receive services from the hospital. 

D.  Populations Exempt from Collection Activities

The following individuals and patient populations are exempt from any collection or billing procedures pursuant to state regulations and policies 613.08(3): 

(1).     Patients enrolled in a public health insurance program, including but not limited to, MassHealth, and Health Safety Net, including those with MAGI Household income or Medical Hardship Family Countable Income between 150.1 to 300% of the FPL; and Medical Hardship, subject to the following: 

a.     The Hospital may seek collection action against any patient enrolled in the above mentioned programs for their required co-payments and deductibles that are set forth by each specific program.

b.     The Hospital may also initiate billing or collection for a patient who alleges that he or she is a participant in a financial assistance program that covers the costs of the Hospital services, but fails to provide proof of such participation.  Upon receipt of satisfactory proof that a patient is a participant in a financial assistance program, (including receipt or verification of signed application) The Hospital shall cease its billing or collection activities.

c.     The Hospital may continue collection action on any Low Income Patient for services rendered prior to the Low Income Patient determination, provided that the current Low Income patient status has been terminated or expired.  However, once a patient is determined eligible and enrolled in the Health Safety Net, MassHealth, the Premium Assistance Payment Program operated by the Health Connector, the Children’s Medical Security Plan, or Medical Hardship, the Hospital will cease collection activity for services (with the exception of any copayments and deductible)  provided prior to the beginning of their eligibility.

d.     The Hospital may seek collection action against any of the patients participating in the programs listed above for non-covered services that the patient has agreed to be responsible for, provided that the Hospital obtained the patient’s prior written consent to be billed for the service.

e.     The Hospital will not undertake collection action against an individual that has been approved for Medical Hardship under the Massachusetts Health Safety Net program with respect to the amount of the bill that exceeds the Medical Hardship contribution.

(2)  The Hospital will not garnish a Low Income Patient’s wages (as determined by the Office of Medicaid) or their guarantor’s wages or execute a lien on the Low Income Patient’s or their guarantor’s personal residence or motor vehicle unless:

• The Hospital can show the patient or their guarantor has the ability to pay.
• The patient/guarantor did not respond to hospital requests for information or the patient/guarantor refused to cooperate with the Hospital to seek an available financial assistance program.
• For purposes of the lien, it was approved by the MRMC Board of Trustee on an individual case by case basis.

(3)  Pursuant to its internal financial assistance program, the Hospital may cease any collection or billing actions against a patient who is unable to pay the Hospital bill at any time during the billing process.  The Hospital will keep any and all documentation that shows that the patient met the Hospital’s internal financial assistance program.

(4)  MRMC and its agents shall not continue collection or billing on a patient who is a member of a bankruptcy proceeding, except to secure its rights as a creditor in the appropriate order.  Finally, the Hospital and its agents will not charge interest on an overdue balance for a Low Income Patient or for patients who are low income based on the Hospital’s own internal financial assistance program.

(5)  MRMC maintains compliance with applicable billing requirements, including the Department of Public Health regulations (105 C.M.R. 130.332) for non-payment of specific services or readmissions that the hospital determines was the result of a Serious Reportable Event (SRE).  SREs that do not occur at the Hospital are excluded from the determination of non-payment. The Hospital also does not seek payment from a low income patient determined eligible for the Health Safety Net program whose claims were initially denied by an insurance program due to an administrative billing error by the Hospital 

E.   Extraordinary Collection Actions

(1)  The Hospital will not undertake any “extraordinary collection activities” until such time as the Hospital has made a reasonable effort and followed a reasonable review of the patient’s financial status, and other information necessary to determine eligibility for financial assistance, which will determine that a patient is entitled to financial assistance or exemption from any collection or billing activities under this credit and collection policy.  The Hospital will keep any and all documentation that was used in this determination pursuant to the Hospital’s applicable record retention policy.  Extraordinary collection activities may include lawsuits, liens on residences, arrest, body attachments, selling debt, reporting to a credit reporting agencies or credit bureau, attaching or seizing bank account or personal property or as otherwise described below in compliance with state requirements.

(2)  The Hospital will not undertake collection action against an individual that has been approved for Medical Hardship under the Massachusetts Health Safety Net program with respect to the amount of the bill that exceeds the Medical Hardship contribution.  The Hospital will further cease any collection efforts against an emergency bad debt claim that is approved for Medical Hardship under the Health Safety Net program.

(3)  The Hospital will not garnish a Low Income Patient’s wages (as determined by the Office of Medicaid) or their guarantor’s wages or execute a lien on the Low Income Patient’s or their guarantor’s personal residence or motor vehicle unless:

• The Hospital can show the patient or their guarantor has the ability to pay.
• The patient/guarantor did not respond to hospital requests for information or the patient/guarantor refused to cooperate with the Hospital to seek an available financial assistance program.
• For purposes of the lien, it was approved by MRMC Board of Trustee on an individual case by case basis.

(4)  The Hospital and its agents shall not continue collection on billing of a patient who is a member of a bankruptcy proceeding except to secure its rights as a creditor in the appropriate order, provided that the state of Massachusetts will file its own recovery action for those patients enrolled in MassHealth or the Health Safety Net.  The Hospital and its agents will also not charge interest on an overdue balance for a Low Income Patient or for patients who are low income based on the Hospitals own internal financial assistance program.

(5)  The Hospital maintains compliance with applicable billing requirements, including the Department of Public Health regulations (105 CMR 130.332) for non-payment of specific services or readmissions that the hospital determines was the result of a Serious Reportable Event (SRE).  SREs that do not occur at the Hospital are excluded from the determination of non-payment. The Hospital also does not seek payment from a low income patient determined eligible for the Health Safety Net program whose claims were initially denied by an insurance program due to an administrative billing error by the Hospital. 

F.  Outside Collection Agencies

MRMC contracts with outside collection agencies to assist in the collection of certain accounts, including patient responsible amounts not resolved after 120 days of continuous collection actions. However, as determined through this credit and collection policy, the Hospital may assign such debt as bad debt or charity care (otherwise deemed as uncollectible) prior to 120 days if it is able to determine that the patient was unable to pay following the Hospital’s own internal financial assistance program.

The Hospital has a specific contract with outside collection agencies and requires such agencies to abide by the Hospital’s credit and collection policies for those debts that the agency is pursuing.  All outside collection agencies hired by MRMC will provide the patient with an opportunity to file a grievance and will forward to the Hospital the results of such patient grievances.  The Hospital requires that any outside collection agency that is used is licensed by the Commonwealth of Massachusetts and that the outside collection agency also is in compliance with the Massachusetts Attorney General’s Debt Collection Regulations at 940 CMR 7.00

G. Hospital Financial Assistance Programs

MRMC, pursuant to an internal review of each patient’s case, may offer a patient an additional discount on an unpaid bill as authorized by the Hospital’s Chief Financial Officer or his/her designee.  Any such review shall be part of an internal hospital financial assistance program that is applied on a uniform basis to patients, and which takes into consideration the patient’s financial situation and the patient’s inability to make a payment after reasonable collection actions.  Any discount that is provided by the Hospital is consistent with the federal and state requirements, and is not based on an effort to induce a patient to receive services from the Hospital or to generate business that is payable by a federal or state program.  

V.   Deposits and Installment Plans

Pursuant to the Massachusetts Health Safety Net regulations pertaining to patients that are either:

(1)      Determined to be a “Low Income Patient”; or

(2)      Qualify for Medical Hardship

The Hospital provides the follow deposits and installment plans.  Any other plan will be based on the Hospital’s own internal financial assistance program, and will not apply to patients who have the ability to pay.

A.  Emergency Services

A hospital may not require pre-admission and/or pre-treatment deposits from individuals that require Emergency Level Services or that are determined to be Low income Patients.

B.   Low Income Patient Deposits

A hospital may request a deposit from individuals determined to be Low Income Patients.  Such deposits must be limited to 20% of the Medical Hardship contribution up to $500.  All remaining balances are subject to the payment plan conditions established in 101 CMR 613.08(1) (g). 

C.  Deposits for Medical Hardship Patients

A hospital may request a deposit from patients for Medical Hardship.  Deposits will be limited to 20% of the Medical Hardship contribution up to $1,000.  All remaining balances are subject to the payment plan conditions established in 101 CMR 613.08(1) (g).

D.  Payment Plans for Low Income Patients pursuant to the Massachusetts Health Safety Net Program

An individual with a balance of $1,000 or less, after initial deposit, must be offered at least a one-year payment plan, interest free with a minimum monthly payment of no more than $25.  A patient that has a balance of more than $1,000, after initial deposit, must be offered at least a two-year interest free payment plan.

VI.    Glossary

Financial Assistance Programs

A program that is intended to assist low-income patients who do not otherwise have the ability to pay for their health care services.  Such assistance should take into account each individual’s ability to contribute to the cost of his or her care.  Consideration is also given to patients who have exhausted their insurance benefits and/or exceed financial eligibility criteria but face extraordinary medical costs.  A financial assistance program is not a substitute for employer-sponsored, public financial assistance, or an individually purchased insurance program. 

Low Income Patient

There are three categories of Low Income Patients:

• Health Safety Net – Primary.

This patient has an income between 0 and 200% of the Federal Poverty Level.

• Health Safety Net – Secondary.

This patient has an income between 0 and 200% Federal Poverty Level.

• Health Safety Net – Partial.

This patient has an income between 201% and 400% Federal Poverty Level.  The individual is responsible for a deductible.

Health Care Services

Hospital level services (provided in either an inpatient or outpatient setting) that is reasonably expected to prevent, diagnose, prevent the worsening of, alleviate, correct, or cure conditions that endanger life, cause suffering or pain, cause physical deformity or malfunction, threaten to cause or to aggravate a handicap, or result in illness or infirmity.

Resident

A person living in Massachusetts with the intention to remain permanently or for an indefinite period.  A resident is not required to maintain a fixed address.  Enrollment in a Massachusetts institution of higher learning or confinement in a Massachusetts medical institution, other than a nursing facility, is not sufficient to establish residence.

State Public Programs include:

• MassHealth: A Public health insurance program for low income Massachusetts residents that covers all or a part of the healthcare services.
• Commonwealth Care:  A health insurance program for low income Massachusetts residents who don’t have health insurance.
• Commonwealth Choice:  A health insurance program for uninsured adult Massachusetts residents that do not qualify for MassHealth.
• Insurance Partnership: Provide health insurance for uninsured employees as well as self-employed workers.
• Children’s Medical Security Plan: A health insurance program for uninsured Massachusetts residents under 19 and do qualify for MassHealth.
• Healthy Start:  Prenatal and postpartum care for uninsured women.
• Prescription Advantage:  Prescription drug insurance plan for seniors and disabled residents for primary prescription drug coverage.
• Health Safety Net:  A program for Massachusetts residents who are not eligible for health insurance and can’t afford to pay for healthcare services.