Financial assistance and charitable care policy

Financial assistance program purpose

Rogers Behavioral Health System, Inc. (collectively with all of its affiliates and subsidiaries, “Rogers”) is committed to providing financial assistance to persons who have healthcare needs and are uninsured, underinsured, ineligible for a government program, or are otherwise unable to pay for medically necessary care based on their individual financial situation. Consistent with its mission to deliver compassionate, high quality, affordable behavioral healthcare services and to advocate for our community members, Rogers strives to ensure that the financial capacity of people who need healthcare services does not prevent them from seeking or receiving care. Rogers will provide, without discrimination, care for emergency behavioral health conditions to individuals regardless of their eligibility for financial assistance or for government assistance.

Accordingly, this written policy:

1. Includes eligibility criteria for financial assistance including free and discounted care;

2. Describes the basis for calculating amounts charged to patients eligible for financial assistance under this policy;

3. Describes the method by which patients may apply for financial assistance;

4. Describes how Rogers will widely publicize the policy and

5. Limits the amount that the hospital will charge for emergency or other medically necessary care provided to individuals eligible for financial assistance to the amount generally received by the hospital for commercially insured and Medicare patients.

In order to manage its resources responsibly and to allow Rogers to provide the appropriate level of assistance to the greatest number of persons in need, the Board of Directors establishes the following guidelines for the provision of patient financial assistance and charitable care. This policy further serves to establish and ensure a fair and consistent method for the review and completion of requests for charitable medical care to our patients in need.

Financial assistance from Rogers comes with two expectations. Patients are expected to cooperate with Rogers’ procedures for obtaining other forms of payment or financial assistance and to contribute to the cost of their care based on their individual ability to pay.

This policy applies to Rogers’ hospitals, clinics, and technical services offered in the State of Wisconsin (Milwaukee and Waukesha Counties).

Policy Statements

It is the policy of Rogers to offer financial assistance to patients who are unable to pay their hospital and/or clinic bills due to difficult financial situations. A Rogers financial counselor, designated Patient Financial Services (“PFS”) staff, or committees with authority to offer financial assistance will review individual cases and determine what level of financial assistance may be offered.

Rogers determines the need for financial assistance by reviewing the particular services requested or received, insurance coverage or other sources of payment, a person’s historical financial profile, and current financial situation. This method allows for a fair and accurate way to assist patients who are experiencing financial hardship. Partial and/or full charitable care will be granted based on the individual’s ability to pay the bill.

Eligible individuals include patients who do not have insurance and patients who have insurance but are underinsured. Patients must cooperate with any insurance claim submission and exhaust their insurance or potential insurance coverage before becoming eligible for financial assistance.

Other factors affecting eligibility are as follows:

• Income - Assuming that other financial resources are not identified as viable funding sources, the Federal Poverty Income Guidelines will be used in determining the amount of charitable care.

• Evaluation of assets - the patient’s household savings, checking, investment assets, real property assets, and overall financial position will be considered.

• Evaluation of the patient’s monthly expenses - review of living expenses includes medical expenses and other basic needs.

• Nature of the medical condition or care required - consideration of services unique to Rogers versus potential of local facilities providing care.

• Considerations - Any special circumstances that the patient would like Rogers to consider.

Eligibility is contingent upon patient cooperation with the application process, including Medicaid or financial assistance application completion where applicable, and submission of all information that Rogers deems necessary in order to determine the level of any financial assistance that may be considered, including written permission for Rogers to check consumer credit information.

Rogers is committed to upholding the federal and state laws that preclude discrimination on the basis of race, color, creed, national origin, religion, sex, sexual orientation, disability, source of income, marital status, sexual orientation, disabilities, military service, or any other classification protected by federal, state or local laws.

Definitions

Bad debt is the cost of providing care to persons who are able but unwilling to pay all or some portion of the medical bills for which they are responsible.

Emergency Care: Care provided to stabilize a medical condition where the patient presents an imminent threat to themselves or others.

Financial Assistance is the cost of providing free or discounted care to individuals who cannot afford to pay, and for which Rogers ultimately does not expect payment. Rogers may determine inability to pay before or after medically necessary services are provided. This is also referred to as Charitable Care. Only Medically Necessary Care will be eligible for Financial Assistance /Charitable Care.

Medically Necessary Care: Services or supplies that are determined by Rogers to be:

• Consistent with the illness or condition of the patient;

• The most appropriate supply or level of service that can safely be provided;

There is no other equally effective, more conservative or substantially less costly course of treatment available or suitable in accordance with generally accepted behavioral health practice guidelines to the person requesting the services.

Eligibility criteria for financial assistance

This policy applies only to charges for emergency care and other Medically Necessary Care provided by Rogers.

Subject to the other eligibility criteria noted in this policy, individuals or families whose annual household income is at or below 100% of the current Federal Poverty Guidelines will be considered eligible for full Financial Assistance.

For individuals and families ineligible for full Financial Assistance, Rogers will grant partial Financial Assistance to those with an annual household income between 100 and 400% of the Federal Poverty Guidelines.  Subject to the other eligibility criteria noted in this policy, Financial Assistance for such individuals and families will be calculated as a percentage of total eligible charges according to the following schedule:

Percentage of Federal Poverty Guidelines	Percentage of Financial Assistance
100%	100%
125%	87%
150%	75%
175%	60%
200%	50%
225%	44%
250%	38%
275%	32%
300%	25%
325%	19%
350%	13%
375%	7%
400%	0%

Depending upon the specific circumstances, an individual Rogers’s facility may provide partial Financial Assistance to individuals and families with income levels exceeding 400% of the Federal Poverty Guidelines, depending on the market served and other financial assistance options available within the community.

The appropriate Patient Financial Services representative will review all circumstances surrounding a request for Financial Assistance. Rogers will notify the patient about the decision within a reasonable time after a complete application has been submitted.

All information regarding a patient’s financial assistance application will be kept confidential. In the event that the patient is not able to provide certain documentation requested, Rogers may rely upon a written and signed statement from the patient specifying the necessary information to make a final determination of eligibility for Charitable Care.

Patients must first exhaust all other funding sources for which they may be eligible before they will be eligible for Charitable Care, including, without limitation, the following:

• Group or individual medical plans

• Medicare

• Worker’s compensation plans

• Medicaid program (patient should have proof of denial)

• Other state, federal or military programs

• Third party liability (i.e., auto accidents, personal injury)

• Any other persons or entities who have legal responsibility to pay for the medical service

In determining whether an individual qualifies for Charitable Care, other county or governmental assistance programs will be considered. Many applicants are not aware that they may be eligible for public health insurance programs or have not pursued application. Rogers requires compliance with the application process of appropriate service organizations that may provide coverage for care, such as Medicaid or Medical Assistance. Rogers’ PFS staff will help the individual determine eligibility for governmental or other assistance, as appropriate. Persons who are eligible for programs (such as state-sponsored Medicaid) but who were not covered at the time that medical services were provided may be granted financial assistance, provided that the patient completes an application for government assistance.

Delivery of financial assistance does not obligate Rogers to provide continuing assistance. Patients may be required to re-apply every 90 days or at the request of a Rogers location.

Rogers makes every reasonable attempt to collect from insurance companies and other third- party payers. Financial hardship and financial assistance adjustments may be considered for those patients whose income and assets will not allow full payment within a reasonable time. Financial hardship assistance may consist of:

• Full adjustment of the self-pay balance

• Partial adjustment of the self-pay balance

• Alternate or extended payment options

Rogers locations reserve the right to reverse financial assistance adjustments and pursue appropriate reimbursement or collections. This may occur as a result of a variety of reasons, including newly discovered information such as insurance coverage or pursuit of a personal injury claim related to the services in question.

Rogers also reserves the right to require confirmation that a patient is ineligible for alternative funding sources, including, without limitation, written denials (or oral denials followed by documentation) from applicable funding sources.

Limitations

Rogers’ financial assistance does not include all costs that may be associated with behavioral health services. Items or services that are not included in the financial assistance program include, but are not limited to, transportation, lodging, prescriptions, food, medical equipment, and pharmacy supplies.

Also, from time to time, Rogers Behavioral Health Foundation’s Angel Fund may offer limited funds in certain short-term situations.

Procedure for financial assistance identification of patients who may be eligible

Prior to receiving services, there are a number of ways a patient can be identified and evaluated for financial assistance prior to, during, or following care. The following is a non-exhaustive list of examples for identification prior to receiving services:

• Patients or their representatives may request financial assistance.

• Rogers’ employees may refer patients to a financial counselor or Patient Financial Services representative.

• Financial counselors and/or Patient Financial Services staff may identify financial need through conversations with patients regarding billing and payment options.

• Referring physicians may refer patients.

• Collection agencies or attorneys may refer patients back to Rogers.

• Local government agencies may refer patients.

Method of applying for financial assistance

Patients who want to apply for financial assistance, or who have been identified as potentially eligible for financial assistance, will be informed of the application process either before receiving services, if the facts suggest potential eligibility, or after the billing and collection process has begun. The application process may be waived or suspended due to medical necessity, including timing and urgency of care. Patients or their representatives can obtain a financial assistance application at no charge by mail by contacting Patient Financial Services at 833-608-2410 or at Rogers locations including 34700 Valley Road, Oconomowoc, WI 53066 or by downloading and printing the financial assistance application from our website at rogersbh.org.

All patients/guarantors who receive a financial assistance application must complete and return the application, along with the following documents that serve as the minimum information necessary to process the application:

• Proof of completion of medical assistance application process, as applicable;

• Proof of household income (pay stubs for the past 90 days);

• A copy of the three most recent bank statements from all banking or credit union institutions of the household;

• A copy of the two most recent tax returns, including all schedules of patient, spouse, or any person who claims the patient as a tax dependent; and

• Full disclosure of claims and/or income from personal injury and/or accident related claims.

A Patient Financial Services representative will review all returned financial assistance applications.. A patient’s application will be considered after Rogers receives a complete financial assistance application and all required documentation, including current pay stubs, income tax statements, and bank statements, if applicable, and income verification. Rogers reserves the right to request additional documentation before finalizing a request for assistance.

The Financial counselor or Patient Financial Services representative will then consult the financial assistance authorization guidelines and present the application to the appropriate person/committee for consideration. Once a decision has been made for financial assistance, a letter is sent to each applicant advising him or her of the decision. Notification for pre-service financial assistance requests will be sent if time permits.

Rogers may share patient financial assistance information across our locations for the benefit and ease of administering financial assistance to patients seen at multiple sites. No information will be shared outside of Rogers unless authorized or required by law.

Basis for calculating the amounts charged to patients

Patients eligible for financial assistance under this Policy will not be charged individually more than the amount generally billed to individuals who have insurance covering such care (the "AGB"). Rogers calculates one or more AGB percentages using the "look-back method" and including Medicare Fee-For-Service and all private health insurers that pay claims to Rogers, all in accordance with Code Section 501(r). A copy of the AGB calculation description and percentage(s) may be obtained free of charge.

Amounts charged for emergency and medically necessary medical services provided to patients eligible for financial assistance under this policy will not exceed AGB.

Reasons for Denial

Rogers may deny a request for financial assistance for a variety of reasons including, but not limited to:

• Sufficient income

• Sufficient asset level

• Patient is uncooperative or unresponsive to requests for information

• Incomplete Financial Assistance application despite reasonable efforts to work with the patient to obtain information

• Pending insurance or liability claim

• Withholding insurance payment and/or insurance settlement funds, including insurance payments sent to the patient to cover services provided by Rogers, and personal injury and/or accident related claims

Emergency services

Rogers’ policy is to provide emergency behavioral health care to stabilize patients, regardless of their ability to pay. Rogers’ staff are prohibited from engaging in actions that discourage individuals from seeking emergency medical care, such as demanding that emergency patients pay before receiving treatment or permitting debt collection activities in areas of the facility where such activities could interfere with the provision, without discrimination, of emergency medical care. Following medical evaluation, non-emergent patients requiring financial assistance consideration will be reviewed and approved before additional services are provided.

Collection activity

Rogers will not engage in extraordinary collection actions before it makes a reasonable effort to determine whether a patient is eligible for financial assistance under this policy. Collection activity will proceed based on a separate collections policy. A free copy of this billing and collections policy may be obtained 34700 Valley Rd, Oconomowoc, WI 53066 or at rogersbh.org

If a collection agency identifies a patient as meeting Rogers’s financial assistance eligibility criteria, the patient’s account may be considered for financial assistance. Collection activity will be suspended on these accounts and Rogers will review the financial assistance application. If the entire account balance is adjusted, the account will be returned to Rogers. If a partial adjustment occurs, the patient fails to cooperate with the financial assistance process, or if the patient is not eligible for financial assistance, collection activity will resume.

Confidentiality

Rogers’ staff will uphold the confidentiality and individual dignity of each patient. Rogers will meet all HIPAA requirements for handling personal health information.

Measures to publicize Rogers’ Financial Assistance Policy

Rogers is committed to offering financial assistance to eligible patients who do not have the ability to pay for their medical services in whole or in part. In order to accomplish this charitable goal, Rogers will widely publicize this policy in the communities that the individual Rogers-affiliated sites serve. Further, a notice advising patients that Rogers provides charitable care shall be posted in the reception, admission and check-in areas of the Rogers’ hospitals and clinics. In addition to posting the policy here, written information about Rogers’ charitable care policy shall also be made available to patients at admitting or check-in and any time upon request.