Reexamining Charity Care Policies

An HFMA Healthcare Financial Pulse Resource

Many hospitals are reexamining their charity care policies, and some are realizing they need to be more generous in light of current realities.

The economic recession and increasingly common high-deductible insurance plans pack a double whammy for patients, and a growing number are needing free or discounted care. Meanwhile, many not-for-profit hospitals must report their community benefit expenditures in new detail to the IRS, beginning this year.

In the following case studies, finance leaders at two hospitals share their experiences with revising their financial assistance policies.

Case Study 1

Loma Linda University Medical Center

At  first glance, creating a charity care policy might not seem to require new staff members, a new computer database, and new signage, but those are just a few of the elements of Loma Linda University Medical Center’s revised charity care policy. In fact, the 939-bed medical center in San Bernardino County, Calif., spent more than $1 million in start-up costs to develop and introduce its revised charity policy.

Work started in 2004 as Loma Linda sought to adopt the California Hospital Association’s Voluntary Principles and Guidelines for Assisting Low-Income Uninsured Patients, which calls for charity care or discounted care for individuals whose income is at 300 percent of the federal poverty level (FPL) or below.

That effort gave Loma Linda a head start when California legislators passed a bill regulating the way hospitals bill low-income and self-pay patients. Preparing to comply with the new law, which went into effect in 2007, required all leaders from the revenue cycle to rework their policies and procedures, guided by a painstaking review of the law and how Loma Linda could make it work.

“Our hospital attorney, who works on our billing matters, and I probably spent 400 to 500 hours going over it line by line,” says Cynthia Schmidt, vice president of revenue cycle.

Loma Linda’s policy is to provide charity care for patients with income at or below 200 percent of the FPL, and discounted care for those with income at or below 350 percent of the FPL. The policy is supported by extensive communications to ensure that patients understand their financial options, staff screen for available assistance programs, and the hospital is complying with the law.

The result, Schmidt says, is higher patient satisfaction with the medical center’s financial assistance programs and the way staff members communicate with their patients.

“Patients actually thank us because of the time we spend with them to explain their options. We hear, ‘Thank you for treating us with dignity and not embarrassing us,’” says Schmidt. “All of these tools for our staff have really helped the patient as well.”

Sometimes doing the right thing can be costly. The new policy has increased the medical center’s charity care load considerably more than expected. “Our charity care has increased 20 percent,” says Steven Mohr, the medical center’s senior vice president of finance. “That is a very significant dollar amount for a hospital as large as Loma Linda.” A tertiary care hospital, Loma Linda is the only level-one regional trauma center for a four-county area.

To get started with the policy revision, Loma Linda hired an outside consultant to review the previous charity care procedures and draft a new policy, application forms, and an implementation plan. Then Schmidt and staff members from every unit of the revenue cycle worked on the thousands of details required for smooth operation.

“When you roll out a policy for the public, patients, and staff, you want to make sure that it’s very clear and that the registration staff and the billing staff can understand the policy,” says Schmidt. “We spent a great deal of time walking through scenarios. ‘What if a patient came through the emergency department? What if the patient had an X-ray? What if….?’”

Implementing the plan involved the following:

  • A new computer database that determines charity care eligibility and keeps statistics
  • Signs, in English and Spanish, displayed in all 19 registration areas across the hospital campus
  • Sixteen new staff members to increase capacity for processing applications and communicating with patients about their financial options
  • New technology that automates some procedures (for example, a new program uses registration data to collect  patient’s credit history, quickly identifying patients who are likely to qualify for charity care)
  • Comprehensive training for all registration, billing, and collection staff, as well as case management, social services, patient relations, and home care workers. 


Interviewed for this case study: Steven Mohr, senior vice president of finance, Loma Linda University Medical Center, Loma Linda, Calif. (smohr@llu.edu), and Cynthia Schmidt, vice president of revenue cycle, Loma Linda University Medical Center (cschmidt@llu.edu).

Case Study 2

Rush University Medical Center

Offering a 50 percent to 70 percent discount to uninsured and underinsured patients seems quite generous. But the CFO of Rush University Medical Center is not bragging. The Chicago hospital’s policies, patterned after some other hospitals around the country, reflect Rush’s particular circumstances, says Catherine A. Jacobson, FHFMA, CPA, 2008-09 chairman-elect of HFMA.

“Each hospital needs to gauge where they are in their own community and how they are serving the uninsured,” she says. A policy that is appropriate for one hospital may not work for another in the same market.

Rush is located next to Chicago’s Stroger (formerly Cook County) Hospital, which is the tertiary hub for low-income patients throughout the city and the surrounding county, as well as a level 1 trauma center. Stroger Hospital’s emergency department (ED) serves many more self-pay and low-income patients than Rush does with its smaller ED. Likewise, some of the other large hospitals in Chicago have up to 50 percent more ED visits than Rush sees, giving these hospitals a much greater burden of uncompensated care in the ED.

“We are in a position where we don’t see the high volumes of uncompensated care through the ED, so we chose to carry our charity responsibilities through other policies,” Jacobson says.

Rush envelops its charity care policy in a tiered system of discounts collectively referred to as financial assistance.

Uninsured patients. All uninsured patients receive at least 50 percent off charges—and low-income patients receive a higher discount or free care.

  • Self-pay patients, regardless of income: 50 percent off charges
  • Self-pay patients with a household income <250 percent of the poverty level: Free care
  • Self-pay: 70 percent off charges
  • Financial hardship patients whose medical bills exceed 70 percent of household income (regardless of income): 70 percent off charges  

Insured patients. Rush’s policy also assists patients with insurance who may end up with large balances due to high deductibles and coinsurance. In this case, the financial assistance policies are applied on top of the insurance plan; a patient with household income below $80,000 would be discounted at 70 percent off charges, including any discount provided by the insurance company (if contracted). In all cases involving insured patients, patients are reviewed for financial status and whether they qualify under the financial assistance policies.

Rush set its 50 percent discount for self-pay patients in recognition of the contracts in place with managed care plans. “People without health insurance are not disadvantaged, in terms of what our charges are, because they don’t have the advantage of the discounts given to insurance companies,” says Jacobson.

The medical center moved to an across-the-board discount for self pay in part because collecting full charges on hospital bills was fruitless, leading to large write offs to bad debt. “It was this ridiculous runaround to try and get people to pay 100 percent of charges,” she says. “We actually collect more now because we’re trying to collect a more reasonable amount.”

Since the more generous financial assistance policies were implemented, Rush has seen its charity care increase—while its bad debt level has decreased. Jacobson believes the policy more accurately categorizes the uncompensated care the medical center delivers—and allows Rush to present an accurate picture of its benefit to the community. Still, the overall cost of providing the expanded financial assistance policies has increased the cost to Rush. 

“We are actually getting credit for giving people real help and it’s showing up in the charity care line,” she says.  


Interviewed for this case study: Catherine A. Jacobson, FHFMA, CPA, senior vice president of strategic planning and finance, CFO, and treasurer, Rush University Medical Center, Chicago (catherine_a_jacobson@rsh.net).

Publication Date: Sunday, March 01, 2009

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