Financial Policies at Breastfeeding Success

1. Eligibility Consideration. Any patient or responsible party with an outstanding patient account is eligible for consideration for financial assistance. Each patient’s or responsible party’s situation will be evaluated according to relevant circumstances, such as income, assets or other resources available to the patient or patient’s family when determining the ability to pay for care. Taking this information into consideration, the attached Financial Assistance Eligibility Criteria Guidelines (See Section IV of the Policy) are utilized to determine what, if any, percentage of the patient’s bill will be discounted.
2. Additional Considerations by Financial Assistance Committee. In certain situations, when a patient’s or responsible party’s circumstances do not satisfy the requirements under the Financial Eligibility Criteria Guidelines, a patient may still be able to obtain financial assistance based on hardship or other circumstances. As further set forth below, in these situations the Provider’s Financial Assistance Committee will review all available information and make a determination on the patient’s eligibility for financial assistance.

1. Identification of Cases.

a. The Provider will make information about its financial assistance program available on its website and on each bill that is sent out to any patients and will endeavor to inform all Eligible Patients of the financial assistance program and how to apply for such assistance pursuant to this Policy.b. Patients or their responsible party who desire to apply for financial assistance shall complete a Financial Assistance Application form (See Exhibit A) and return it to the address specified on the Financial Assistance Application.

b. Patients or their responsible party who desire to apply for financial assistance shall complete a Financial Assistance Application form (See Exhibit A) and return it to the address specified on the Financial Assistance Application.

2. Financial Assistance Determination Process.

a. All financial assistance applications will be forwarded to the Provider’s Practice Manager where they will be evaluated according to established Financial Assistance application processing procedures.

b. The Practice Manager will determine if the application qualifies for financial assistance and if not, it shall automatically forward the Financial Assistance Application to the Provider’s Financial Assistance Committee for its review.

3. Recordkeeping and Reporting Financial Assistance.

a. All completed Financial Assistance applications and supporting documentation will be retained and kept on file for 7 years.

4. Patient Responsibility.

a. There is no assurance that because a patient completes a Financial Assistance Application that the patient will qualify for financial assistance.

b. It is ultimately the patient’s responsibility to provide the necessary information to qualify for financial assistance. In order for the Provider to process a Financial Assistance Application, the patient must provide the Provider with all of the information requested on the Financial Assistance Application. If the patient is unable to provide the Provider with an item requested in the application, the patient must provide the Provider with documentation explaining such inability.

1. If based on the information in the financial assistance application, the patient is determined to be eligible to receive financial assistance on the provider charges. For the purposes of this policy, “provider charges” means the full billed charge for all services provided by the provider, including professional services and other ancillary services.

2. The level of financial assistance will be based on the eligible patient’s classification as financially indigent, medically indigent, or uninsured patient, in accordance with the below. The discounts set forth below and elsewhere in this Policy applies solely to the Provider Charges and do not apply to patients liabilities such as co-pays, deductibles, and co-insurance.

A. Medically Indigent Patients.

a. “Medically Indigent” means a patient whose Total Yearly Income exceeds 200% of the Federal Poverty Guidelines, but whose medical bills after payment by all third parties exceed 5% of their Total Yearly Income and who is unable to pay the remaining bill. For the purposes of this Policy, the term “Total Yearly Income” means the sum of the total yearly gross income of the patient or the responsible party.

b. If a patient is determined to be Medically Indigent, then such patient may qualify for a 50% discount.

B. Financially Indigent Patients. 

a. “Financially Indigent” means an uninsured or underinsured patient whose Total Yearly Income is less than or equal to 200% of the Federal Poverty Guidelines.

b. These patients are eligible for a 100% discount on the Provider Charges.

c. The criteria used to determine if a patient is classified as Financially Indigent is contained in Exhibit B of this Policy.

C. Uninsured Patients.

a. An “Uninsured Patient” means a patient who does not have any third party insurance. For the avoidance of doubt, a patient is not considered an Uninsured Patient if they have insurance, but the services they receive from Provider is not covered by their insurance.

b. It is the Provider’s policy to provide all Uninsured Patients based on the sliding scale outlined on Exhibit C.”

3. Financial Assistance Committee. 

a. In certain situations, it may be appropriate to grant a patient financial assistance even though the patient’s financial situation does not satisfy the requirements set forth in Provider’s Financial Assistance Eligibility Criteria Guidelines.

b. In these situations, the Financial Assistance Application and other pertinent information may be reviewed by the Provider’s Financial Assistance Committee, who will make a determination as to the patient’s eligibility for financial assistance.

1. Income Verification – Application. The patient or responsible party shall provide the patient’s reported Total Yearly Income on the signed Financial Assistance Application.
2. Income Verification – Verbal Attestation. In cases where the patient or responsible party is unable to fill out a Financial Assistance Application signed by the responsible party attesting to the veracity of the patient’s Total Yearly Income information provided, the income can be verified by obtaining the responsible party’s verbal attestation. The Practice Manager or delegated team member completing the Financial Assistance Application must attest in writing that the responsible party verbally verified the patient’s Total Yearly Income information provided.

V. NON-PAYMENT

After a patient’s account is reduced by any discounts available under this Policy, the patient or responsible party will be responsible for the remainder of his or her outstanding patient accounts. Patients will be invoiced for any remaining amounts in accordance with the Provider’s Billing & Collections Policy.

The Provider’s Billing & Collections Policy describes in further detail the collection actions that may be taken by the Provider in the event of non-payment of bills.

1. Certain Services Not Covered. The Provider reserves the right to exclude certain services from coverage under this Financial Assistance Policy.
2. Third Party Settlement. A Financial Assistance Application will be denied if the patient receives a third party financial settlement associated with the care rendered by the Provider. Such patients are expected to use the settlement amount to satisfy any bills.

Billing & Collections Policy

This Billing & Collections Policy (this “Policy”) sets forth the standards and processes by which Breastfeeding Success Company, LLC (the “Company”) conducts its billing and collection practices. It is the goal of this policy to provide clear and consistent guidelines for conducting billing and collection functions in a manner that promotes legal compliance, patient satisfaction, and efficiency.

Through the use of billing statements, written correspondence, and phone calls, the Company will make diligent efforts to inform patients of their financial responsibilities and available financial assistance options (including through the Company’s Financial Assistance Policy), as well as follow-up with patients regarding outstanding accounts. 

Additionally, this policy requires the Company to make reasonable efforts to determine a patient’s eligibility for financial assistance under the Company’s Financial Assistance Policy, which include providing patients, when appropriate, with written and oral notifications about the Financial Assistance Policy and the application process. 

General Billing and Collection Process

The Company uses the same reasonable efforts and follows the same reasonable process for collecting amounts due for services provided to all patients, including insured, underinsured, or uninsured patients. Collection activities may occur during the preregistration process and will continue until account resolution. 

1. The collection process may include requests for deposits, payment plans or discretionary settlements. 
2. The collection process may involve the use of outside collection agencies, which may include reporting the outstanding balance to credit reporting agencies. 
3. The collection process is documented in the patient’s account files accessible to the hospital and its business associates involved in the collections process. 

Insurance Billing

1. For all insured patients, the Company will bill applicable third-party payors (based on information provided by or verified by the patient) in a timely manner.
2. If a claim is denied (or is not processed) by a payor due to an error on the Company’s party, the Company will not bill the patient for any amount in excess of what the patient would have owed had the payor paid the claim.
3. If a claim is denied (or is not processed) by a payor due to factors outside of the Company’s control, the Company’s staff will follow-up with the payor and the patient as appropriate to facilitate resolution of the claim. If resolution does not occur after prudent and timely follow-up efforts, then the Company may bill the patient or take other actions consistent with current regulations and industry standards.

Patient Billing

1. If a patient qualifies for the Financial Assistance Program, they will receive the discount of their billed charge in accordance with the Financial Assistance Policy. 
2. All uninsured patients will be billed directly and timely, and they will receive a statement as part of the organization’s normal billing process.
3. For insured patients, after claims have been processed by third-party payers, the Company will bill patients in a timely fashion for the patient responsibility portion of their claims  as determined by their insurance benefits.
4. All patients may request an itemized statement for their accounts at any time.
5. If a patient disputes his or her account and requests documentation regarding the bill, Company staff members will provide the requested documentation in writing within ten (10) days (if possible) and will hold the account for at least thirty (30) days before referring the account for collection.
6. The Company may approve payment plan arrangements or a negotiated settlement for patients who indicate they may have difficulty paying their balance in a single installment or otherwise.
7. The Company is not required to accept patient-initiated payment arrangements or negotiated settlements and may refer accounts to a collection agency as outlined below if the patient is unwilling to make acceptable payment arrangements or negotiated settlements or has defaulted on an established payment plan or negotiated settlement.

Collection Practices

The Company may engage in collection actions, including Standard Collection Actions, to collect outstanding patient balances. For the purposes of this Policy, “Standard Collection Action (SCA)” means a list of collection activities that the Company will take against a patient to obtain payment for care after reasonable efforts have been made to collect payment from a patient and to determine whether the patient is eligible for financial assistance under the Financial Assistance Policy.

1. General collection activities may include follow-up calls to patients and written collection notices sent to patients.
2. Patient balances may be referred to a third-party for collection at the discretion of the Company. Accounts will be referred for collections only with the following caveats:
   1. There is a reasonable basis to believe the patient owes the debt; 
   2. All third-party payors have been properly billed, and the remaining debt is the financial responsibility of the patient (i.e., the Company will not bill a patient for any amount that an insurance company is obligated to pay);
   3. The Company will not refer accounts for collection while a claim on the account is still pending payor payment; provided, that the Company may classify certain claims as “denied” if such claims are stuck in “pending” mode for an unreasonable length of time despite efforts to facilitate resolution; and
   4. The Company will not refer accounts for collection where the patient has applied for financial assistance and the Company has not yet notified the patient of the Company’s determination as to whether the patient is eligible for financial assistance (so long as the patient has complied with the timeline and information requests as part of the financial assistance application process).
   5. The Company may choose not to collect a patient debt if the total amount due from  the patient is $7.00 or less, as this would mean the cost of collection would be more than the amount due.
3. Before engaging in any SCAs to obtain payment for care, the Company will take reasonable efforts to determine whether a patient is eligible for financial assistance under the Company’s Financial Assistance Policy. Prior to initiating SCAs to obtain payment, the Company will therefore:
   1. Provide the patient with a written notice that indicates the availability of financial assistance, provides a copy of the Financial Assistance Policy, lists potential SCAs that may be taken to obtain payment for care, and gives a deadline after which time SCAs may be initiated; and
   2. Attempt to notify the patient orally about the Financial Assistance Policy and how the patient may get assistance with the financial assistance application process. 
4. After making the reasonable efforts noted above to determine the patient’s financial assistance eligibility, the Company may take pursue SCAs against the patient, which may include referring outstanding patient balances to third-parties for collection and/or reporting adverse information to credit reporting agencies and/or credit bureaus.

Customer Service

During the billing and collection process, the Company will provide quality customer service through the following guidelines:

1. The Company will enforce a zero tolerance standard for abusive, harassing, offensive, deceptive, or misleading language or conduct by its employees and staff; and
2. The Company will maintain a streamlined process for responding to patient questions and/or disputes, including contact information for the Company which will be listed on all patient bills and any collection statements sent.