2016-698 Emergency Svc - North State Medical Transport - Application for Services Franchise by Ordinance

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Policy on Hardship Waivers of Coinsurance and Deductibles I. INTRODUCTION A.It is the policy of NSMT that all NSMT employees will make reasonable and consistent attempts to collect co- insurance and unpaid deductible amounts from patients.There are two exceptions to this collection rule:(1)if the patient is truly indigent and the patient's financial hardship has been established or if it is not cost-effective to collect the outstanding amount,the collection of these amounts may be waived.In the case of financial hardship,a Hardship Waiver Form will be signed by the patient. B. Items and services provided to patients of NSMT are reimbursed primarily through payments from third party payers and secondarily through payments from patients.Patient participation in the cost of health care has the effect of reducing the cost incurred by payers as well as creating a financial incentive for patients to be cost conscious consumers.Both Medicare law and contracts with third party payers require reasonable attempts to collect coinsurance and unpaid deductible amounts from NSMT patients. According to the Office of the Inspector General,the routine waiver of co-insurance and deductible amounts is considered to be a violation of Medicare law,which can result in: False Claims.-By routinely waiving co-insurance and deductible amounts,providers are indicating a willingness to accept a lesser charge.The assumption is made that the lower amount is actually the charge and that the provider is submitting false claims. Violations of the Anti-Kickback Statute-Routine waivers can be interpreted as an inducement to entice patients to a particular health care provider.Such an inducement violates the anti-kickback statute. Excessive Utilization-Routine waivers of co-insurance and deductible amounts can be viewed as encouragement by providers for patients to receive care that may not be needed because there is no out-of-pocket expense involved.This result in excessive utilization of items and services paid for by the third party payer. Medicare fraud and abuse laws have been extended to private insurance through the health insurance Portability and Accountability Act of 1996. GUIDELINES: Demonstrating a "Reasonable Attempt" A. Patients requesting Hardship Waivers ("Applicants") will be considered on a case by case basis. The total number of patients receiving waivers at the same time will be at the discretion of the NSMT CEO. B. An attempt to collect co-insurance and deductible amounts is considered reasonable and consistent if NSMT's Billing Contractor uses the same reasonable policy of collection for all patient accounts. Therefore, NSMT's Billing Contractor will use the same billing techniques, the same internal and external collections techniques, etc., for all similar accounts regardless of the desire to collect the patient balance. In situations in which it costs more to bill the patient than the amount being collected, these amounts may be waived. NSMT's patient accounts department will provide documentation for this exception to be valid. 32