Billing and Collections Policy and Procedure
After our patients have received services, it is the policy of Flagler
Hospital to bill patients and applicable payers accurately and in a timely
manner. During this billing and collections process, staff will provide
quality customer service and timely follow-up, and all outstanding accounts
will be handled in accordance with the IRS and Treasury’s 501(r)
final rule under the authority of the Affordable Care Act.
It is the goal of this policy to provide clear and consistent guidelines
for conducting billing andcollections functions in a manner that promotes
compliance, patient satisfaction, and efficiency. Through the use of billing
statements, written correspondence, and phone calls, Flagler Hospital
will make diligent efforts to inform patients of their financial responsibilities
and available financial assistance options, as well as follow up with
patients regarding outstanding accounts. Additionally, this policy requires
Flagler Hospital to make reasonable efforts to determine a patient’s
eligibility for financial assistance under Flagler Hospital’s financial
assistance policy before engaging in extraordinary collection actions
to obtain payment.
Extraordinary Collection Actions (ECAs): A list of collection activities, as defined by the IRS and Treasury, that
healthcare organizations may only take against an individual to obtain
payment for care after reasonable efforts have been made to determine
whether the individual is eligible for financial assistance. These actions
are further defined in Section II of this policy below and include actions
such as reporting adverse information to credit bureaus/reporting agencies
along with legal/judicial actions such as garnishing wages.
Financial Assistance Policy (FAP): A separate policy that describes Flagler Hospital’s financial assistance
program—including the criteria patients must meet in order to be
eligible for financial assistance as well as the process by which individuals
may apply for financial assistance.
Reasonable Efforts: A certain set of actions a healthcare organization must take to determine
whether an individual is eligible for financial assistance under Flagler
Hospital’s financial assistance policy. In general, reasonable efforts
may include making presumptive determinations of eligibility for full
or partial assistance as well as providing individuals with written and
oral notifications about the FAP and application processes.
I. Billing Practices
A. Insurance Billing
- For all insured patients, Flagler Hospital will bill applicable third-party
payers (as based on information provided by or verified by the patient)
in a timely manner.
- If a claim is denied (or is not processed) by a payer due to an error on
our behalf, Flagler Hospital will not bill the patient for any amount
in excess of what the patient would have owed had the payer paid the claim.
- If a claim is denied (or is not processed) by a payer due to factors outside
of our organization’s control, staff will follow up with the payer
and patient as appropriate to facilitate resolution of the claim. If resolution
does not occur after prudent follow- up efforts, Flagler Hospital may
bill the patient or take other actions consistent with current regulations
and industry standards.
B. Patient Billing
- All uninsured patients will be billed directly and timely, and they will
receive a statement as part of the organization’s normal billing process.
- For insured patients, after claims have been processed by third-party payers,
Flagler Hospital will bill patients in a timely fashion for their respective
liability amounts as determined by their insurance benefits.
- All patients may request an itemized statement for their accounts at any time.
- If a patient disputes his or her account and requests documentation regarding
the bill, staff members will provide the requested documentation in writing
within 10 days (if possible) and will hold the account for at least 30
days before referring the account for collection.
- Flagler Hospital may approve payment plan arrangements for patients who
indicate they may have difficulty paying their balance in a single installment.
- Patient Financial Services Management has the authority to make exceptions
to this policy on a case-by-case basis for special circumstances.
- Flagler Hospital is not required to accept patient-initiated payment arrangements
and may refer accounts to a collection agency as outlined below if the
patient is unwilling to make acceptable payment arrangements or has defaulted
on an established payment plan.
II. Collections Practices
- In compliance with relevant state and federal laws, and in accordance with
the provisions outlined in this Billing and Collections Policy, Flagler
Hospital may engage in collection activities—including extraordinary
collection actions (ECAs)—to collect outstanding patient balances.
- General collection activities may include [follow-up calls on statements]
- Patient balances may be referred to a third party for collection at the
discretion of Flagler Hospital. Accounts will be referred for collections
only with the following caveats:
- There is a reasonable basis to believe the patient owes the debt.
- All third-party payers have been properly billed, and the remaining debt
is the financial responsibility of the patient. Flagler Hospital shall
not bill a patient for any amount that an insurance company is obligated to pay.
- Flagler Hospital will not refer accounts for collection while a claim on
the account is still pending payer payment. However Flagler Hospital 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.
- Flagler Hospital will not refer accounts for collection where the claim
was denied due to a Flagler Hospital error. However, Flagler Hospital
may still refer the patient liability portion of such claims for collection
- Flagler Hospital will not refer accounts for collection where the patient
has initially applied for financial assistance or other Flagler Hospital
sponsored program and Flagler Hospital has not yet notified the patient
of its determination (provided the patient has complied with the timeline
and information requests delineated during the application process).
- Reasonable Efforts and Extraordinary Collection Actions (ECAs)
- Before engaging in ECAs to obtain payment for care Flagler Hospital must
make certain reasonable efforts to determine whether an individual is
eligible for financial assistance under our financial assistance policy:
- ECAs may begin only when 120 days have passed since the first post-discharge
statement was provided.
- However, at least 30 days before initiating ECAs to obtain payment, Flagler
Hospital shall do the following:
- Provide the individual with a written notice that indicates the availability
of financial assistance, lists potential ECAs that may be taken to obtain
payment for care, and gives a deadline after which ECAs may be initiated
(no sooner than 120 days after the first post-discharge billing statement
and 30 days after the written notice)
- Provide a plain-language summary of the FAP along with the notice described above
- Attempt to notify the individual orally about the FAP and how he or she
may get assistance with the application process
- After making reasonable efforts to determine financial assistance eligibility
as outlined above Flagler Hospital (or its authorized business partners)
may take the following ECA to obtain payment for care:
- Report adverse information to credit reporting agencies and/or credit bureaus
- If a patient has an outstanding balance for previously provided care, Flagler
Hospital may engage in the ECA of deferring, denying, or requiring payment
before providing additional medically necessary (but non-emergent) care
only when the following steps are taken:
- Flagler Hospital provides the patient with an FAP application and a plain
language summary of the FAP
- Flagler Hospital provides a written notice indicating the availability
of financial assistance and specifying any deadline after which a completed
application for assistance for the previous care episode will no longer
be accepted. This deadline must be at least 30 days after the notice date
or 240 days after the first post-discharge billing statement for prior
care—whichever is later.
- Flagler Hospital makes a reasonable effort to orally notify the individual
about the financial assistance policy and explain how to receive assistance
with the application process.
- Flagler Hospital processes on an expedited basis any FAP applications for
previous care received within the stated deadline
- Patient Financial Services is ultimately responsible for determining if
an individual is eligible for financial assistance. This body also has
final authority for deciding whether the organization may proceed with
any of the ECAs outlined in this policy.
III. Financial Assistance
All billed patients will have the opportunity to contact Flagler Hospital
regarding financial assistance for their accounts, payment plan options,
and other applicable programs.
- Flagler Hospital’s financial assistance policy is available free
Request a copy:
- In person at any registration location at Flagler Hospital
- By calling the Billing Department/Financial Advocate 904-819-4539 or mailing
a request to 2155 Old Moultrie Rd Suite 103, St. Augustine, FL 32086
- Online at http://www.flaglerhospital.org/
- Individuals with questions regarding Flagler Hospital’s financial
assistance policy may contact the financial counseling office by phone
at 904-819-4539 or in person at 400 Health Park BLVD, St. Augustine, FL 32086
IV. Customer Service
- During the billing and collection process, Flagler Hospital will provide
quality customer service by implementing the following guidelines:
- Flagler Hospital will enforce a zero tolerance standard for abusive, harassing,
offensive, deceptive, or misleading language or conduct by its employees.
- Flagler Hospital will maintain a streamlined process for patient questions
and/or disputes, which includes a toll-free phone number patients may
call and a prominent business office address to which they may write.
This information will remain listed on all patient bills and collections
- After receiving a communication from a patient (by phone or in writing),
Flagler Hospital staff will return phone calls to patients as promptly
as possible (but no more than one business day after the call was received)
and will respond to written correspondence within 10 days.
- Flagler Hospital will maintain a log of patient complaints (oral or written)
that will be available for audit.