Statement of Purpose
The Mount Sinai Hospitals Group, Inc. ("MSHG"), The Mount Sinai Hospital, Beth Israel Medical Center, The St. Luke’s Roosevelt Hospital Center, and the New York Eye & Ear Infirmary (collectively the "MSHG Member Hospitals") recognize that many of the patients served in the MSHG Member Hospitals may be unable to access quality health care services without financial assistance. This Financial Assistance and Billing and Collections Policy (the "Policy") was developed to ensure that the MSHG and the MSHG Member Hospitals continue to uphold their mission of providing quality health care to the community, while carefully taking into consideration the ability of the patient to pay, as applied in a fair and consistent manner.
Definitions
"MSHG Member Hospitals" means Beth Israel Medical Center ("MSBI"), The St. Luke's-Roosevelt Hospital Center ("MSW", "MSSL"), The New York Eye and Ear Infirmary ("NYEEI"), and The Mount Sinai Hospital ("MSH").
“MSHG Member Hospital Facilities” or “Hospital Facilities” means those facilities that are a part of either MSBI, MSW, MSSL, NYEEI, or MSH, that are licensed by New York State to operate as "Article 28" hospital facilities and that are listed in Section 8 of this Policy.
“Emergency Medical Care” means care provided by the MSHG and or the MSHG Member Hospitals, at any of the MSHG Member Hospital Facilities, for emergency medical conditions.
“Financial Assistance Application Period” means the period ending on the 240th day after the first post-discharge billing statement is provided to a patient.
“ISMMS” means the Icahn School of Medicine at Mount Sinai.
“Medically Necessary Care” means items and services that are reasonable and necessary for the diagnosis or treatment of illness or injury or to improve the functioning of a malformed body member.
Policy Administration
The Mount Sinai Department of Patient Financial Services has ownership, control, and responsibility for administration of this Policy. Patients who need assistance with the financial assistance application process should contact:
Policy
It is MSHG and MSHG Member Hospital policy that patients who meet the eligibility criteria and apply for financial assistance as set forth herein will receive financial assistance for Emergency Medical Care and other Medically Necessary Care rendered in the MSHG Member Hospital Facilities by the MSHG and the MSHG Member Hospitals themselves (including providers employed by or contracted directly by the MSHG Member Hospitals).
In addition, as set forth in this Policy and in the Appendices to this Policy, patients who meet the eligibility criteria set forth in this Policy and apply for financial assistance as set forth herein may be entitled to receive financial assistance for Emergency Medical Care and other Medically Necessary Care rendered in the MSHG Member Hospital Facilities by providers who are directly employed by or contracted by ISMMS.
Eligibility Criteria for Financial Assistance Under This Policy
Eligibility for Emergency Medical Care: Patients may be eligible for financial assistance for Emergency Medical Care under this Policy if:
Eligibility for non-emergency Medically Necessary Care: Patients may be eligible for financial assistance for non-emergency Medically Necessary Care under this Policy if:
Patients are ineligible for financial assistance for Emergency Medical Care or other non-emergency Medically Necessary Care under this Policy if:
Services For Which Financial Assistance Is Or May Be Available Under This Policy
Financial assistance is available under this policy for Emergency Medical Care and other Medically Necessary Care rendered in the MSHG Member Hospital Facilities by either: (1) the MSHG; or (2) the MSHG Member Hospitals (including providers employed by or contracted by those hospitals). Appendices A - D to this Policy contain lists that set forth, for each MSHG Member Hospital: (1) the names of all of the providers and entities (as appropriate) that provide Emergency Medical Care and/or Medically Necessary Care in each such MSHG Member Hospital; (2) the affiliation and/or employment status of each such provider; and (3) the extent to which, if at all, financial assistance under this Policy is available for such services provided by those providers. These Appendices can be accessed online at www.hospitalassistance.org, or can be obtained in hard copy upon request to any of the offices listed in Section 3 herein.
Financial assistance may be available under this Policy for certain Emergency Medical Care and other Medically Necessary Care rendered in the MSHG Member Hospital Facilities that is billed to patientsby providers who are either directly employed by or contracted by ISMMS, depending on the nature and scope of the services at issue and the patient’s eligibility for financial assistance. The Appendices to this Policy contain information regarding the extent to which, if at all, financial assistance is available for such services rendered at the MSHG Member Hospital Facilities by ISMMS providers; additional information regarding whether or not financial assistance is available under this Policy for services rendered at the MSHG Member Hospital Facilities by ISMMS providers may be available atwww.hospitalassistance.org.
Services For Which Financial Assistance Is Not Available Under This Policy
Financial assistance is not available under this policy for the following types of care and services:
MSHG Member Hospital Facilities To Which This Policy Applies
This Policy and the financial assistance provided under this Policy is available only for Emergency Medical Care and other Medically Necessary Care rendered by qualifying providers at the following hospital facilities (the “MSHG Member Hospital Facilities”):
Specific Financial Assistance Available Under This Policy
A patient who is determined to be entitled to financial assistance for Emergency Medical Care or other Medically Necessary Care under this Policy is entitled to a discount in accordance with the Sliding Fee Scale Discount Table attached as Appendix E (the “Discount Table”).
A patient who is determined to be entitled to financial assistance for Emergency Medical Care or other Medically Necessary Care under this Policy will not be charged more for hospital services than the amount generally billed by the applicable MSHG Member Hospital for such Emergency Medical Care or other Medically Necessary Care Consistent with federal regulations, the MSHG Member Hospitals set the amount generally billed at the total amount the Medicare fee-for-service program would allow for the care (i.e., the amount Medicare and the Medicare beneficiary together would pay for the care).
All uninsured patients are presumptively eligible for the lowest level of discount available under the Discount Table for Emergency Medical Care and other Medically Necessary Care provided by the MSHG Member Hospitals themselves (including providers who are employed by or contracted directly by the MSHG Member Hospitals). The MSHG Member Hospitals will notify such patients that they may apply for additional assistance available under this Policy.
Uninsured patients are not presumptively eligible for financial assistance for bills for Emergency Medical Care and other Medically Necessary Care rendered in the MSHG Member Hospital Facilities by providers who are directly employed by or contracted by ISMMS. In order to receive financial assistance for bills for Emergency Medical Care and other Medically Necessary Care rendered in the MSHG Member Hospital Facilities by providers who are directly employed by or contracted by ISMMS, patients must apply for financial assistance (as set forth in Section 12 herein) and be determined to be entitled to such financial assistance by the appropriate MSHG Member Hospital.
Eligibility/Entitlement Determinations
Determinations of patient eligibility/entitlement to financial assistance under this Policy will be made by the appropriate MSHG Member Hospitals as listed in Section 12 herein.
The MSHG Member Hospitals will determine if a patient has third party coverage. If no third party coverage exists, the MSHG Member Hospitals will determine if the patient is eligible for government insurance programs such as Medicare or Medicaid. If the patient is eligible for Medicaid under the “Emergency Services Only” coverage, or if the patient is eligible for Medicaid but the patient’s Emergency Medical Care or other Medically Necessary Care is not covered by Medicaid, the patient will automatically be deemed eligible for the highest level of financial assistance available under this Policy or, if the patient is employed, will be given the applicable discount under the Discount Table. No further documentation will be required other than confirmation from the State of New York of the patient’s Medicaid status. If a patient is not eligible for government insurance programs and meets the requirements set forth in Section 5 of this Policy, the patient will be eligible to apply for financial assistance under this Policy.
Eligibility Period
If a patient is approved for financial assistance under this Policy, such eligibility shall not exceed one year commencing on the first day of the month in which services were first delivered or up to the last day of the month of the next “open enrollment period” as established under the Affordable Care Act, whichever comes first. If the patient requires an ambulatory surgery procedure or inpatient hospitalization, the MSHG Member Hospitals may require the patient to recertify the patient’s eligibility for financial assistance under this Policy.
How to Apply for Financial Assistance Under This Policy
Patients may apply for financial assistance under this Policy by completing and submitting a Financial Aid Application form to the MSHG Member Hospital at which the services were rendered, at the following addresses:
Patients will be required to provide the following documentation with the Financial Aid Application form (documentation must meet the standards of proof applied by Medicaid to Medicaid application documentation):
The MSHG and the MSHG Member Hospitals will not deny a patient financial assistance under this Policy based on the patient’s failure to provide any information unless the information is specifically requested in this Policy or on the Financial Aid Application form.
Deposits
Any deposit paid by a patient as part of the financial assistance program will be included in the overall discount package.
Payment Determination
When patient has been determined eligible for financial assistance, an appropriate discount will be determined based on the current Discount Table. The patient or responsible party will be notified in writing of eligibility and if eligible and if applicable, asked to sign a payment agreement. A New York State surcharge will be added to all amounts determined to be the patient’s responsibility, as appropriate under the Health Care Reform Act. Payment terms shall be compliant with the existing New York State Financial Assistance Law. Payment terms shall not exceed the limits as set forth under the New York State Financial Assistance Law and shall not include interest (all installment plans are interest free). Installment plans (if any) shall not exceed 10% of the head of household gross monthly income in accordance with the New York State Financial Assistance Law for persons who qualify under this policy.
Appeals of Eligibility Determinations
A patient has the right to appeal decisions regarding financial assistance within 30 days of notification of non-eligibility. Appeals can only be submitted based on the following:
The Departments of Patient Financial Services (as appropriate depending on where the subject services were rendered (see lists below)) will decide appeals in cases as specified above.
Appeals should be made in writing (or in person, by appointment) to the following:
Appeals decisions will be issued within 10 business days of receipt of a patient appeal (i.e., after receipt of letter or an in-person appeal). The DFC, at its discretion, may request that an application or additional appeal be filed for government sponsored benefits as part of the financial aid appeal process.
Follow-Up Information
Patients are responsible for promptly reporting changes in financial status and/or contact information to the appropriate MSHG Member Hospital. If a patient or responsible party is unable to comply with a signed payment agreement they must contact the appropriate MSHG Member Hospital. If a patient or responsible party defaults on a payment agreement with the appropriate MSHG Member Hospital, the account in question will be considered delinquent and the MSHG Member Hospital reserves its right to refer the patient’s account to an outside collection service, where appropriate, consistent with guidelines set forth in section 16 of this Policy and with applicable law.
Training
The MSHG and the MSHG Member Hospitals will assure that all staff responsible for engaging or otherwise assisting on the application for services covered by this Policy are trained on this Policy.
Actions That May Be Taken In The Event of Non-Payment
The MSHG and the MSHG Member Hospitals (or other authorized party) may take the following actions in the event that a patient does not pay a bill for medical care:
The MSHG and the MSHG Member Hospitals will not take any of the following actions against a patient who does not pay for Emergency Medical Care or other Medically Necessary Care:
Limitations on Legal Actions
The MSHG and the MSHG Member Hospitals will not initiate any legal action for payment for Emergency Medical Care or other Medically Necessary Care provided to a patient until at least 120 days from the date of the first post-discharge billing statement to the patient for the care. Prior to taking any legal action against a patient or against any other individual who has accepted or is required to accept responsibility for the patient’s hospital bill, the MSHG and/or the MSHG Member Hospitals will make reasonable efforts to determine whether the patient is eligible for financial assistance under this Policy, as follows:
The Mount Sinai Patient Financial Services Department will have final responsibility for determining that the MSHG or the applicable MSHG Member Hospital has made reasonable efforts to determine whether a patient is eligible for financial assistance under this Policy and may therefore engage in legal action against the patient.
If, after the MSHG or the applicable MSHG Member Hospital makes reasonable efforts to determine whether a patient is eligible for financial assistance, the MSHG or the applicable MSHG Member Hospital begins a legal action against the patient, and the patient then submits a financial assistance application before the end of the Financial Assistance Application Period, the MSHG and/or the applicable MSHG Member Hospital will suspend the legal action, determine whether the patient is eligible for financial assistance, and notify the patient of this determination (including any assistance for which the patient is eligible) and the basis for the determination. If the patient is determined to be eligible for assistance, the MSHG or the applicable MSHG Member Hospital will:
Collection Agency Policy
The MSHG and the MSHG Member Hospitals instruct all collection agencies that they must follow the principles outlined in this Policy. Any legal actions will be subject to the provisions of Section 19 of this Policy, and will only be approved in cases where the MSHG and/or the MSHG Member Hospitals determine that a patient has the means to pay outstanding balances. For all legal actions, the collection agency must present documentation to the MSHG or the applicable MSHG Member Hospital supporting such action.
Policy Administration and Maintenance
The MSHG and the MSHG Member Hospitals will centralize the reporting of the data for decisions rendered under this Policy and document such in the Mount Sinai Department of Patient Financial Services accounting system. Such centralization will be limited only to decisions rendered under the terms of this Policy for the purposes of compliance with the New York State Hospital Financial Assistance Law and Internal Revenue Code Section 501(r). The MSHG and the MSHG Member Hospitals will collect and distribute information to the MSHG and the MSHG Member Hospitals’ management teams and Boards of Trustees regarding this Policy. This Policy and the activities described herein are subject to internal audits.
Availability of this Policy
The MSHG and the MSHG Member Hospitals will widely publicize this Policy by:
List of Appendices to this Policy
Appendix A: List of Providers providing Emergency Care or other Medically Necessary Care at BIMC Hospital Facilities
Appendix B: List of Providers providing Emergency Care or other Medically Necessary Care at SLR Hospital Facilities
Appendix C: List of Providers providing Emergency Care or other Medically Necessary Care at NYEEI Hospital Facilities
Appendix D: List of Providers providing Emergency Care or other Medically Necessary Care at MSH Hospital Facilities
Appendix E: Discount Table
These Appendices can be accessed online at www.hospitalassistance.org, or can be obtained in hardcopy upon request to any of the department of patient financial services offices listed herein.