Online Program

Community benefits and Schedule H: Holding nonprofit hospitals accountable for their financial policies and practices

Wednesday, November 6, 2013 : 10:30 a.m. - 10:45 a.m.

Jessica Curtis, JD, Hospital Accountability Project, Community Catalyst, Boston, MA
“Community benefits” are health-related investments and activities, other than fully reimbursed medical care, that a hospital provides to its community. Community benefit obligations can arise in several legal contexts (e.g. condition of licensure, conversions or health planning processes) but are most commonly associated with tax-exempt hospitals. Section 9007 of the Affordable Care Act (ACA) established new requirements and reporting standards nonprofit hospitals must satisfy for federal tax exemption. These provisions clarify and promote transparency of tax-exempt hospitals' efforts to meet federal community benefit responsibilities in four areas: community health needs assessment, financial assistance policies, limitations on hospital charges, and billing and debt collection requirements. The latter requirements respond partly to persistent reports by national media involving hospital mistreatment and overreaching with respect to indigent, uninsured, and underinsured patients. This presentation will focus on the ACA's requirements relating to nonprofit hospital financial assistance, charges, billing, and collections practices, and how the ACA requirements have been translated into enforceable standards through IRS reporting requirements (Schedule H). It will discuss how hospital billing and collections practices can impact patient behavior and economic stability, as well as which populations are likely to continue to rely on hospital financial assistance despite expanded coverage through the ACA. Finally, it will highlight promising approaches some hospitals and regulators are using to improve hospital practices and patient experiences. The audience for this session includes public health lawyers and practitioners involved in community-based population health improvement initiatives; public health professionals without legal expertise; and state and local policymakers.

Learning Areas:

Ethics, professional and legal requirements
Other professions or practice related to public health
Provision of health care to the public
Public health or related laws, regulations, standards, or guidelines
Public health or related organizational policy, standards, or other guidelines
Public health or related public policy

Learning Objectives:
Define new financial assistance, billing and collection requirements in the ACA. Describe the populations likely to continue to need financial assistance post-ACA expansion and the implications for hospital and community health planning. Demonstrate the potential impacts of hospital billing and collection practices on patient health and economic opportunity. Identify promising approaches state and local regulators and hospitals are using to improve hospital billing and collection practices.

Keyword(s): Accountability, Public Policy

Presenting author's disclosure statement:

Qualified on the content I am responsible for because: As Project Director for the Hospital Accountability Project since 2009, I have administered and provided technical assistance to subgrantees in 15 states on hospital billing and collections law and policy; analyzed and published a compendium of relevant state laws; and served as a national expert for the media, Members of Congress, HHS, and the IRS as it works to develop final rules in this area.
Any relevant financial relationships? No

I agree to comply with the American Public Health Association Conflict of Interest and Commercial Support Guidelines, and to disclose to the participants any off-label or experimental uses of a commercial product or service discussed in my presentation.