Billing and Collection Policy

I. Policy

It is the policy of Martin Health System (MHS) to make reasonable efforts to determine whether an individual is eligible for assistance under its Financial Assistance Policy (FAP). If patients do not apply for assistance and do not pay their balance, the account may be sent to a collection agency. Charity is always preferred to sending patient balances to an agency.

II. Definitions

• a. AGB – Amounts generally billed for emergency or other medically necessary care to individuals who have insurance coverage. 
• b. Application Period – means the period during which MHS must accept and process an application for financial assistance under its FAP in order to have made reasonable efforts to determine whether the individual is FAP-eligible. The Application Period begins on the date the care is provided to the individual and ends on the 240th day after MHS provides the individual with the first billing statement for the care. 
• c. MHS – Martin Health System. 
• d. Completion Deadline – means the date after which MHS may initiate or resume ECAs (defined below) against an individual who has submitted an incomplete FAP application if that individual has not provided MHS with the missing information and/or documentation necessary to complete the application. The completion deadline must be specified in a written notice and must be no earlier than the later of 30 days after MHS provides written notice, or the last day of the Application Period. 
• e. ECAs – Extraordinary Collection Actions are actions taken by MHS against an individual related to obtaining payment of a bill for care covered under MHS’s FAP that require a legal or judicial process or involve selling an individual’s debt to another party or reporting adverse information about the individual to consumer credit reporting agencies or credit bureaus. 
• f. FAP – Financial Assistance Policy. 
• g. FAP-Eligible Individual – An individual eligible for financial assistance under MHS’s FAP (without regard to whether the individual has applied for assistance under the FAP). 
• h. Notification Period – means the period during which MHS must notify an individual about its FAP in order to have made reasonable efforts to determine whether the individual is FAP-eligible. The notification period begins on the first date care is provided to the individual and ends on the 120th day after MHS provides the individual with the first billing statement for the care. 

III. Billing and Collection Guidelines

a. It is the policy of MHS not to engage in ECAs against an individual before making reasonable efforts to determine whether the individual is eligible for assistance under its FAP. 

b. Consistent with the provisions herein, balances will not be sent to a collection agency prior to 120 days of first statement to patient. Charity consideration will still be given to patients whose balances are with a collection agency. 

c. Patients will be sent a letter, in addition to their final statement, informing them their account is being sent to a collection agency. Patients have 30 days to respond to letter. 

d. Subject to the guidelines set forth herein, MHS patient accounts may be subject to the following collection actions: 

• i. Credit bureau reporting (which will not take place until after 120 days from first statement to patient); 
• ii. MHS may also pursue legal action against patients who do not qualify for assistance and have sufficient assets to cover the unpaid balances greater than 240 days outstanding. Legal action may result in a lien on property. Legal action will not be taken until approved by the Revenue Cycle Director or Assistant Vice President.
• iii.  MHS may sell a patients debt (balance due) to another party when normal collection practices do not result in payment.

e. Determining Financial Assistance Eligibility

• i. As a means of determining whether individuals are eligible for financial assistance under its FAP, MHS will notify individuals about its FAP during the Notification Period as follows: 
• 1. Offer a plain language summary of the FAP and offer a FAP application form to individuals before discharge.
• 2. Include a plain language summary of the FAP with all (and at least three) billing statements for the care and all other written communications regarding the bill provided to individuals during the Notification Period (each statement/notice/letter to patient will be sent 30 days apart);
• 3. Inform individuals about the FAP in all oral communications regarding the amount due for their care that occur during the Notification Period; and
• 4. Provide individuals with at least one written notice that informs them about the ECAs that MHS (or other authorized party) may take if they do not submit a FAP application or pay the amount due by a deadline (specified in the notice) that is no earlier than the last day of the Notification Period, and is provided to the individual at least 30 days before the deadline specified in the written notice.
• ii. MHS will process FAP applications in accordance with the provisions set forth below. 

f. Processing Financial Assistance Applications

• i. Submission of Complete Financial Assistance Application 
• 1. If an individual submits a complete FAP application during the Application Period, MHS will—
• a. Suspend any ECAs against the individual (with respect to charges to which the FAP application under review relates);
• b. Make and document a determination as to whether the individual is FAP-eligible;
• c. Notify the individual in writing of the eligibility determination (including, if applicable, the assistance for which the individual is eligible) and the basis for this determination;
• d. If MHS determines the individual is FAP-eligible—
• i. Provide the individual with a billing statement that indicates the amount the individual owes as a FAP-eligible individual and shows, or describes how the individual can get information regarding, the AGB for the care and how the hospital facility determined the amount the individual owes as a FAP-eligible individual;
• ii. If the individual has made payments to MHS (or any other party) for the care in excess of the amount he or she is determined to owe as a FAP-eligible individual, refund those excess payments; and
• iii. Take all reasonably available measures to reverse any ECA (with the exception of a sale of debt) taken against the individual to collect the debt at issue.
• 2. If the provisions of Section 1 above are met, and MHS has not violated the anti-abuse rule described in Section IV below, MHS may initiate or resume ECAs against the individual.
• ii. Submission of Incomplete Financial Assistance Application
• 1. If an individual submits an incomplete FAP application during the Application Period, MHS will—
• a. Suspend any ECAs against the individual (with respect to charges to which the FAP application under review relates);
• b. Provide the individual with a written notice that describes the additional information and/or documentation required under the FAP or FAP application form that the individual must submit to MHS to complete his/her FAP application and include a plain language summary of the FAP with the notice; and
• c. Provide the individual with at least one written notice that—(1) informs the individual about the ECAs MHS (or other authorized party) may initiate or resume if the individual does not complete the FAP application or pay the amount due by the Completion Deadline, and (2) is provided to the individual at least 30 days before the Completion Deadline.
• i. If the FAP application is completed by the Completion Deadline, the individual will be considered to have submitted a complete FAP during the Application Period.
• ii. If the FAP application is not completed by the Completion Deadline, and MHS has met the requirements described in this Section, MHS may initiate or resume ECAs against the individual after the Completion Deadline.
• iii. Failure to Submit Financial Assistance Application 
• If an individual fails to submit a FAP application during the Notification Period, MHS shall follow the notification provisions above, and (until and unless the individual subsequently submits a FAP application during the remainder of the Application Period) MHS may engage in ECAs against the individual. 

IV. Miscellaneous Provisions

• a. Anti-Abuse Rule – MHS will not base its determination that an individual is not FAP-eligible on information that MHS has reason to believe is unreliable or incorrect or on information obtained from the individual under duress or through the use of coercive practices. 
• b. Presumptive Eligibility – MHS will have made reasonable efforts to determine whether an individual is FAP-eligible if MHS determines that the individual is eligible for the most generous assistance (including free care) available under the FAP based on information other than that provided by the individual as part of a complete FAP application and MHS meets the requirements described above with regard to processing complete FAP applications. 
• c. No Waiver of FAP Application – MHS will not seek to obtain a signed waiver from any individual stating that the individual does not wish to apply for assistance under the FAP, or receive the notifications described above, in order to make a determination of FAP eligibility. 
• d. Final Authority for Determining FAP Eligibility – Final authority for determining that MHS has made reasonable efforts to determine whether an individual is FAP-eligible and may therefore engage in ECAs against the individual rests with the Revenue Cycle Director or Assistance Vice President.

V. Physician Providers

• All physicians bill separately and independently
• You will receive bills for Emergency Physician, Radiologist, Cardiologist, consulting physicians, and Pathologist separately
• For more information about these separate bills click here