©2008 office of massachusetts attorney general martha coakley community benefits guidelines office...

©2008 Office of Massachusetts Attorney General Martha Coakley

Community BenefitsGuidelines

Office of Attorney General Martha Coakley

February 23, 2009

Community Benefits

History of Guidelines

• Non-profit, acute care hospitals – 1994• HMOs - 1996• Non-regulatory approach

• Voluntary principles• Agreement of stakeholders• Public reporting

• Grounded in charitable role of hospitals and HMOs



Community Benefits

Advisory Task Force

• Attorney General Coakley convened a Community Benefits Advisory Task Force in January, 2008.

• Members included hospital and HMO representatives, health care and consumer advocates, representatives from DPH, community health centers, and academia.

Community Benefits

Goal of Review

The Attorney General asked the Task Force to consider how to: • encourage pre-planning and measurement• encourage a focus on Statewide priorities• improve the reporting process• to provide training and acknowledge

successful programs©2008 Office of Massachusetts Attorney General Martha Coakley


Community Benefits

• Accountability • Transparency• Process

• Pre-planning• Community

Involvement

• Statewide Priorities• Streamlined

Reporting• Address Medical

Debt

Highlights of Revision


Community Benefit Principles

•Community Benefit Mission Statement•Leadership Support for Community Benefits Plan•Community Involvement•Community Health Needs Assessment•Community Benefits Plan•Community Benefit Report

Community Benefits

Community Benefits

Statewide Priorities

• Supporting Health Care Reform• Chronic Disease Management• Reducing Health Disparities• Promoting Wellness of Vulnerable

Populations


Community Benefits

Community Benefits Mission Statement

• Public statement setting forth hospital or HMO’s commitment to provide resources and support for implementation of its annual Community Benefit Plan.


Community Benefits

Leadership

• Hospital or HMO should demonstrate support for Community Benefits at the highest levels of the organization.


Community Benefits

Community Involvement

• The Hospital or HMO should ensure regular community involvement in the planning and implementation of the Community Benefits Plan.


Community Benefits

Community Health Needs Assessment

• To develop Mission and Plan, the hospital or HMO should conduct a comprehensive review of the unmet health needs of the community, analyzing• public health data;• community input; and• existing programs.


Community Benefits

Community Benefits Plan

• The Plan should include the Target Populations on which the hospital or HMO will focus and the specific programs/activities designed to address needs

• Program Goals and Measurement• Definition of “Community Benefit Program”



Community Benefits

Report

• Process reporting- the process of developing the Plan

• Program reporting – detailed info on programs, including goals/measures

• Expenditure reporting

Community Benefits

Community Benefit Expenditures

• Hospitals and HMOs should determine amount of community benefit expenditures based on financial factors

• No fixed target level of expenditures• AGO will review expenditures in context of

hospital/HMO’s reported financial status and resources



Optional Reporting

• Community service programs• Bad debt – if hospital adopts

recommended medical debt collection practices

• IRS Form 990 community benefit expenditures – for comparison

Community Benefits


Community Benefits

Recommended Medical Debt Collection Practices

• Fair debt collection practices that take into account unique nature of medical debt • reasonable protections for patients• allow providers to seek appropriate reimbursement

• Over and above requirements of state or federal law or regulations

Community Benefits

Examples of Recommended Hospital Debt Collection Practices

• Provide sufficient billing info to patients as well as info about financial assistance opportunities

• Do not assign patient accounts to collection for 120 days

• Require 3d party collection agents to follow hospital credit and collection policies

• Do not report to a credit reporting agency, sell patient debt or garnish wages/seek lien unless specifically approved by the hospital’s board of directors


Community Benefits

Conclusion

Advisory Task Force reached consensus on stronger, more standardized Guidelines that •improve transparency and accountability in community benefit reporting; •encourage pre-planning and community involvement; and •align activities with statewide health priorities, including health disparities

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