Charity Care Policy

Background: The Public Health Provider Charity Care Program (PHP-CCP) is a component of the Texas Medicaid 1115 Waiver, authorized under Section 1115 of the Social Security Act. The program supports public health providers in delivering services to uninsured and underinsured populations by offsetting the costs of uncompensated care. The funding is administered by the Centers for Medicare and Medicaid Services (CMS) and overseen by the Texas Health and Human Services Commission (HHSC).

The PHP-CCP aims to reduce the financial burden on providers while ensuring access to necessary health care services for individuals who cannot afford to pay. Waco-McLennan County Public Health District (WMCPHD) is committed to participating in this program by establishing a clear and equitable policy for determining eligibility and administering charity care.

Purpose: To establish guidelines for providing charity care to eligible individuals in compliance with the Texas HHSC Public Health Provider Charity Care Program (PHP-CCP). This policy ensures compliance with funding requirements under Section 1115 of the Social Security Act, administered by CMS.

Scope: This policy applies to covered public health services provided by Waco-McLennan County Public Health District Clinics to uninsured, underinsured, and other individuals meeting the eligibility criteria outlined below.

Related Standards and Procedures: None

Eligibility: Eligibility for charity care will be considered for those individuals who are uninsured, underinsured, ineligible for any government health care benefit program, and who are unable to pay for public health services, based upon a determination of financial need based on income as defined by the Federal Poverty Level Guidelines (FPG). The granting of charity care shall be based on an individualized determination of financial need, and shall not consider age, gender, race, social or immigrant status, sexual orientation or religious affiliation.

Presumptive Eligibility: Presumptive eligibility may include the following personal/family financial criteria, active participation in, or eligibility for, any of the following programs or circumstances:

1. Earning an Adjusted Gross Income (AGI) less than 400% FPG for household size
2. County Indigent Health Care Program
3. Women, Infants and Children program (WIC)
4. Supplemental Nutritional Assistance Program (SNAP)
5. Temporary Assistance for Needy Families (TANF)
6. Children’s Health Insurance Program (CHIP)
7. Subsidized School Lunch Program
8. Any state or local assistance program (e.g., Medicaid spend-down, Good Health Card)
9. Subsidized housing for home address provided
10. Filed bankruptcy in the 12 months prior to application
11. Any individual invoice/account determined to be uncollectable after three attempts
12. Signed attestation of inability to pay at time of services rendered, or at time of follow-up billing for services not covered by another payor
13. Patients are deceased with no known estate

Patients are not eligible for financial assistance if they:

1. Do not qualify under criteria above
2. Earn annual Adjusted Gross Income (AGI) greater than 400% of the Federal Poverty Guideline (FPG) for household size
3. Decline to fully complete or sign Charity Care Application or supporting documentation

WMCPHD will not consider an incomplete application Additionally, patients seeking certain elective vaccines treatments, or services are classified as full-pay patients, and full payment is required at or before the time of service.

Required Eligibility Documentation: Patients must submit a completed application with attestation of income, and any other relevant information prior to receiving services for which they wish to qualify for Charity Care.

Applications will be reviewed at the time of submission. Applicants will be notified of the determination in writing prior to services rendered.

Applicants may appeal a denied application within 10 [ten] business days by providing additional documentation.

For claims, appeals, interpretations, resolution of problems, and special situations, contact:

Cindy Murphey, RN
Clinical Services Program Manager
cmurphey@wacotx.gov

Covered Services: Public health services intended to protect and promote the general population's health and to prevent higher cost interventions such as hospitalizations. These services include, but are not limited to, tuberculosis identification, diagnosis, and treatment; sexually transmitted diseases identification, diagnosis, and treatment; immunization with recommended or required vaccines (clinical services and administration); and chronic disease screening, monitoring, and self-management.

Procedure: All patients will be treated fairly and with respect before, during, and after services, regardless of their ability to pay. The granting of financial assistance shall be based on an individualized determination of financial need and shall not consider age, gender, race, ethnicity, socio-economic status, sexual orientation, or religious affiliation. All applicable local, state, and federal regulatory requirements were considered in the development of this policy.

Relevant staff will complete annual training on the Charity Care Program to ensure compliance with current policies and procedures.

Funding and Reporting: This policy is funded through PHP-CCP allocations under Section 1115 Waiver. WMCPHD will comply with all PHP-CCP reporting requirements, including annual reporting of uncompensated care data to HHSC.

Definitions

• Charity Care -or- Financial Assistance Program: Public Health services provided without charge or at a reduced rate to individuals meeting the financial assistance eligibility criteria.
• Family: Using the Census Bureau definition, a group of two or more people who reside together and are related by birth, marriage, or adoption. According to Internal Revenue Service rules, if the patient claims someone as a dependent on their income tax return, they may be considered a dependent for the provision of financial assistance.
• Family income: Family Income is determined using the Census Bureau definition, which uses the following income when computing federal poverty guidelines, as attested by the applicant:
  • Includes earnings, unemployment compensation, workers' compensation, Social Security, Supplemental Security Income, public assistance, veterans' payments, survivor benefits, pension or retirement income, interest, dividends, rents, royalties, income from estates, trusts, educational assistance, alimony, child support, assistance from outside the household, and other miscellaneous sources.
  • Excludes noncash benefits (such as food stamps and housing subsidies).
  • Determined on a before-tax basis.
  • Excludes capital gains or losses.
  • Includes the income of all family members who live together (non-relatives, such as housemates, do not count).
• Federal Poverty Guidelines (FPG): The applicable household income thresholds established periodically in the Federal Register by the U.S. Department of Health and Human Services under the authority of 42 U.S.C.~9902(2).
• Gross Charges: The total charges at the organization's full established rates for the provision of patient care services before deductions from revenue are applied.
• Underinsured: The patient has some level of insurance or third-party assistance but still has out-of-pocket expenses that exceed his or her financial abilities.
• Uninsured: The patient has no level of insurance or third-party assistance to assist with meeting his or her payment obligations.

Policy Updates: This policy will be reviewed annually or as required by changes in the PHP-CCP or CMS guidelines.

Participating Providers: This list may be updated if/when additional providers are added for services.

• E. Farley Verner, MD, appointed Health Authority for the Waco-McLennan County Public Health District

Community Communication Plan: Notification about charity care available from WMCPHD shall be disseminated by WMCPHD by various means, which may include, but are not limited to, the publication of notices in patient information packets, and posted notices in clinical areas. WMCPHD may also provide a summary of this charity care policy on facility websites, in brochures available inpatient access sites and at other places within the community served by WMCPHD as WMCPHD may elect. Such notices and summary information shall be provided in the primary languages spoken by the population serviced by WMCPHD. Referral of patients for charity may be made by any member of WMCPHD staff. The patient, or any representative, subject to applicable privacy laws, may make a request for charity.