Financial Assistance Policy

PURPOSE
• Includes eligibility criteria for financial assistance — free and discounted (partial Compassionate Care) care
• Describes the basis for calculating amounts charged to patients eligible for financial assistance under this policy
• Describes the method by which patients may apply for financial assistance
• Describes how the hospital will publicize the policy within the community served by the hospital
• Limits the amounts that the hospital will charge for emergency or other medically necessary
care provided to individuals eligible for financial assistance to amount generally billed
Woodlawn Hospital and any hospital owned clinic is committed to providing Compassionate Care to persons who have healthcare needs and are uninsured, underinsured, ineligible for a government
program, or otherwise unable to pay, for medically necessary care based on their individual financial
situation.
Consistent with its mission to provide excellent healthcare services by highly skilled staff in a
compassionate and caring manner. Woodlawn Hospital recognizes its responsibility to serve patients, employees, physicians, and the community. Woodlawn Hospital strives to ensure that the financial capacity of people who need health care services does not prevent them from seeking or receiving care.
Woodlawn Hospital will provide, without discrimination, care of emergency medical conditions to
individuals regardless of their eligibility for financial assistance or for government assistance.
Accordingly, this written policy:
Compassionate Care. Retrieved 06/2023. Official copy at (received by) the hospital for commercially insured or Medicare patients
I. DEFINITIONS
• Includes earnings, unemployment compensation, workers’ compensation, Social Security,
Supplemental Security Income, public assistance, veterans’ payments, survivor benefits,
pension or retirement income, interest, dividends, rents, royalties, income from estates, trusts,
alimony, child support, assistance from outside the household, and other miscellaneous
sources;
• Noncash benefits (such as food stamps and housing subsidies) do not count;
• Determined on a before-tax basis;
• Excludes capital gains or losses; and
• If a person lives with a family, includes the income of all adult family members (Non-relatives,
such as housemates, do not count).
Compassionate Care is not considered to be a substitute for personal responsibility. Patients are
expected to cooperate with Woodlawn Hospital’s procedures for obtaining Compassionate Care or other
forms of payment or financial assistance, and to contribute to the cost of their care based on their
individual ability to pay. Individuals with the financial capacity to purchase health insurance shall be
encouraged to do so, as a means of assuring access to health care services, for their overall personal
health, and for the protection of their individual assets.
In order to manage its resources responsibility and to allow Woodlawn Hospital 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 Compassionate Care.
For the purpose of this policy, the terms below are defined as follows:
Compassionate Care: Healthcare services that have been or will be provided but are never expected to
result in cash inflows. Compassionate Care results from a provider’s policy to provide healthcare
services free or at a discount to individuals who meet the established criteria.
Family: According to Internal Revenue Service rules, if the patient claims someone as a dependent on
their income tax return, they may be considered a dependent for purposes of the provision of financial
assistance.
Family Income: Family Income is determined using the Census Bureau definition, which uses the
following income when computing federal poverty guidelines:
Uninsured: The patient has no level of insurance or third party assistance to assist with meeting his/her
payment obligations.
Underinsured: The patient has some level of insurance or third-party assistance but still has out-of pocket expenses that exceed his/her financial abilities.
Gross Charges: The total charges at the organization’s full established rates for the provision of patient
care services before deductions from revenue are applied.
Compassionate Care. 
II. PROCEDURES
A. Services Eligible Under this Policy. For purposes of this policy, “Compassionate Care” or
“financial assistance” refers to healthcare services provided by Woodlawn Hospital without
charge or at a discount to qualifying patients. The following healthcare services are eligible for
Compassionate Care:
1. Emergency medical services provided in an emergency room setting;
2. Services for a condition that are considered medically necessary by the provider but
are not elective in nature;
3. Non-elective services provided in response to life-threatening circumstances in a non-emergency room setting.
B. Eligibility for Compassionate Care.
Eligibility for Compassionate Care will be considered for those individuals, who are uninsured,
underinsured, ineligible for any government health care benefit program, and who are unable to
pay for their care, based upon a determination of financial need in accordance with this Policy.
The granting of Compassionate Care shall be based on an individualized determination of
financial need, and shall not take into account age, gender, race, social or immigrant status,
sexual orientation, or religious affiliation. [Woodlawn Hospital shall determine whether or not
patients are eligible to receive Compassionate Care for deductibles, co-insurance, or co-payment
responsibilities.]
C. Method by Which Patients May be determined eligible for Compassionate Care.
1. Financial need will be determined in accordance with procedures that involve an
individual assessment of financial need; and may
• Include an application process, in which the patient or the patient’s
guarantor are required to cooperate and supply personal, financial, and
other information and documentation relevant to making a determination
of financial need;
• Include the use of external publically available data sources that provide
information on a patient’s or a patient’s guarantor’s ability to pay (such as
credit scoring);
• Include reasonable efforts by Woodlawn Hospital to explore appropriate
alternative sources of payment and coverage from public and private
payment programs, and to assist patients to apply for such programs;
• Take into account the patient’s available assets, and all other financial
resources available to the patient; (exclude primary home and car, include
Emergency medical conditions: Defined within the meaning of section 1867 of the Social Security Act
(42 U.S.C. 1395dd).
Medically necessary: As defined by Medicare (services or items reasonable and necessary for the
diagnosis or treatment of illness or injury).
Elective surgery or elective procedure: A surgery that is scheduled in advance because it does not
involve a medical emergency.
bank account balances over $1500.00) and
• Include a review of the patient’s outstanding accounts receivable for prior
services rendered and the patient’s payment history.
2. It is preferred but not required that a request for Compassionate Care and a
determination of financial need occur prior to rendering of non-emergent medically
necessary services. However, the determination may be done at any point in the
collection cycle. The need for financial assistance shall be re-evaluated on a
quarterly basis, or at any time additional information relevant to the eligibility of the
patient for Compassionate Care becomes known.
3. Woodlawn Hospital’s values of respect, caring, and confidentiality shall be reflected
in the application process, financial need determination and granting of
Compassionate Care. Requests for Compassionate Care shall be processed
promptly and Woodlawn Hospital shall notify the patient or applicant in writing
within 15 days of receipt of a completed application.
D. Presumptive Financial Assistance Eligibility.
There are instances when a patient may appear eligible for Compassionate Care discounts, but
there is no financial assistance form on file due to a lack of supporting documentation. Often
there is adequate information provided by the patient or through other sources, which could
provide sufficient evidence to provide the patient with Compassionate Care assistance. In the
event there is no evidence to support a patient’s eligibility for Compassionate Care, Woodlawn
Hospital could use outside agencies in determining estimate income amounts for the basis of
determining Compassionate Care eligibility and potential discount amounts. Presumptive
eligibility may be determined on the basis of individual life circumstances that may include:
1. Homeless or received care from a homeless clinic;
2. Participation in Women, Infants and Children programs (WIC);
3. Eligibility for other state or local assistance programs that are unfunded (e.g.,
Medicaid spend-down); and/or
4. Patient is deceased with no known estate.
E. Eligibility Criteria and Amounts Charged to Patients. Services eligible under this Policy will be
made available to the patient on a sliding fee scale, in accordance with financial need, as
determined in reference to Federal Poverty Levels (FPL) in effect at the time of the
determination. Once a patient has been determined by Woodlawn Hospital to be eligible for
financial assistance, that patient shall not receive any future bills based on undiscounted gross
charges. The basis for the amounts Woodlawn Hospital will charge patients qualifying for
financial assistance will be on a sliding scale based upon a percentage of the current year
federal poverty level.
Patients whose family income exceeds 138% of the FPL may be eligible to receive discounted
rates on a case-by-case basis based on their specific circumstances, such as catastrophic
illness or medical indigence, at the discretion of Woodlawn Hospital; however the discounted
rates shall not be greater than the amounts generally received by the hospital for commercially
insured [or Medicare] patients.
F. Communication of the Compassionate Care Program to Patients and Within the Community.
Notification about Compassionate Care available from Woodlawn Hospital, which shall include
a contact number, shall be disseminated by Woodlawn Hospital by various means, which may
include, but are not limited to, the publication of notices in patient bills and by posting notices
in emergency rooms, admitting and registration departments, hospital business offices,
hospital owned clinics, and at other public places as Woodlawn Hospital may elect. Woodlawn
Hospital also shall publish and widely publicize a summary of this Compassionate Care policy
on facility websites, in brochures available in patient access sites and at other places within
the community served by the hospital as Woodlawn Hospital may elect. Such notices and
summary information shall be provided in the primary languages spoken by the population
serviced by Woodlawn Hospital. Referral of patients for Compassionate Care may be made by
any member of the Woodlawn Hospital staff or medical staff, including physicians, nurses,
financial counselors, social workers, case managers, and hospital chaplains. A request for
Compassionate Care may be made by the patient or a family member, close friend, or
associate of the patient, subject to applicable privacy laws.
G. Relationship to Collection Policies.
Woodlawn Hospital management shall develop policies and procedures for internal and
external collection practices (including actions the hospital may take in the event of non-payment, including collections action, filing liens, and reporting to credit agencies) that take
into account the extent to which the patient qualifies for Compassionate Care, a patient’s good
faith effort to apply for a governmental program or for Compassionate Care from Woodlawn
Hospital, and a patient’s good faith effort to comply with his or her payment agreements with
Woodlawn Hospital. For patients who qualify for Compassionate Care and who are
cooperating in good faith to resolve their discounted hospital bills, Woodlawn Hospital may
offer extended payment plans, will not send unpaid bills to outside collection agencies, and will
cease all collection efforts. Woodlawn Hospital will not impose extraordinary collections
actions such as wage garnishments; liens on primary residences, or other legal actions for any
patient without first making reasonable efforts to determine whether that patient is eligible for
Compassionate Care under this financial assistance policy.
Reasonable efforts shall include:
1. Validating that the patient owes the unpaid bills and that all sources of third-party
payments have been identified and billed by the hospital;
2. Documentation that Woodlawn Hospital has or has attempted to offer the patient
the opportunity to apply for Compassionate Care pursuant to this policy and that the
patient has not complied with the hospital’s application requirements;
3. Documentation that the patient has been offered a payment plan but has not
honored the terms of that plan.
H. Regulatory Requirements. In implementing this Policy, Woodlawn Hospital management and
facilities shall comply with all other federal, state, and local laws, rules, and regulations that
may apply to activities conducted pursuant to this Policy.