EMS Cost Recovery Administrative Policy Decisions
1. Compassionate Billing
The compassionate billing policy for Albemarle County will provide that “if you cannot pay, you won’t have to pay.” If a patient cannot pay any portion of a bill that is not otherwise collectible through insurance billing, he or she will not be required to pay anything and the unpaid balance will not be sent to a collection agency.
By submitting a simple and non-intrusive “Hardship Billing Waiver” form (provided upon request from the billing company), all patients will be able to resolve their bills in a manner that meets their financial needs without any risk or stigma.
2. Waiver of Deductibles or Co-pays
The County Executive’s Office does not recommend, at this time, that the County follow the Office of Inspector General’s opinions regarding a waiver of deductibles and co-payments.
The Department of Health and Human Services, Office of Inspector General (OIG) has provided advisory opinions to various entities which state, in simplified terms, that a locality does not violate federal anti-kickback statutes if it waives otherwise applicable co-payments and deductibles due from residents by considering these fees paid through local taxes. The opinions do not provide for a waiver of the applicable fees for non-residents of the billing locality.
Our billing company, Diversified Ambulance Billing (DAB), advises that its various clients, including Albemarle’s surrounding localities, divide roughly 50-50 on this matter. Louisa, Hanover and Chesterfield, for example, do not waive deductibles and co-payments; Orange, Nelson and Spotsylvania do.
Localities which choose to waive deductibles and co-payments consider these costs covered by local tax payments, although they do not reconcile individual patient costs with the amount of taxes paid. These localities only collect the fees allowed by private insurance and Medicare/Medicaid. Localities which do not waive deductibles and co-payments reason that: a) even the most robust collection of fees would not come close to paying for the actual system costs of emergency services; b) citizens are accustomed to other pay-as-you-go fees such as building permits; and c) the locality already follows a compassionate billing protocol whereby residents with financial hardship will not be responsible for paying the balance of uncovered fees. Furthermore, since the County will be billing many non-County residents, such as Charlottesville, Fluvanna, and Greene residents, staff believes it would be more equitable and efficient to have consistent billing practices for the entire region served by the County’s career and volunteer rescue squads.
3. Subscription Program
The County Executive’s Office does not recommend establishing a subscription program at this time.
Subscription programs allow citizens to pay an annual fee (usually approximately $60) in lieu of paying any out-of-pocket expenses for that year. By law, their insurance companies still must be billed. Some localities choose this option believing that there will be a high demand for it. However, according to DAB, subscription programs tend to be highly underutilized by those localities that offer them. In addition, DAB reports that our surrounding localities are split on this issue. Orange, Nelson and Spotsylvania do not offer it; Louisa, Hanover and Chesterfield do.
In addition, since the County will be implementing a sensitive compassionate
billing policy, citizens may perceive an inconsistency between offering
discounted rates through a subscription program, on the one hand, and forgiving
bills for financial hardship, on the other. A subscription program may always
be considered later, should the data and public response show it to be valuable.
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