Clarifications on Required Changes to Hospital Financial Assistance and Community Benefits Reporting
December 7, 2021
Memorandum
Three pieces of legislation passed earlier this year (Public Acts 102-004, 102-0504 and 102-0581) require hospitals to make changes to their financial assistance process/applications and community benefit reporting, if applicable. IHA’s comprehensive summary can be found here and in a subsequent memo on effective dates.
The Office of Attorney General (OAG) sent a letter to IHA providing further clarification on Public Act 102-0581 relating to the financial assistance application/process and community benefit reporting. A similar letter is planned to be sent to each hospital. (Note several clarifications will likely be made to the letter before being sent to hospitals: pg. 2 will clarify the revised benchmark for qualifying for a discount under the Hospital Uninsured Patient Discount Act applies only to urban hospitals; pg. 3 will clarify information regarding maximum collectible amount is to be included in financial assistance information, not necessarily the application; pg. 4 may clarify hospital reports that include time periods in 2021 and 2022).
Financial Assistance Application/Process
All hospitals licensed in Illinois are subject to the Hospital Uninsured Patient Discount Act. Public Act 102-0581 requires the financial assistance application to include information related to where to direct questions/concerns as well as a specific statement: “Complaints or concerns with the uninsured patient discount application process or hospital financial assistance process may be reported to the Health Care Bureau of the Illinois Attorney General”. A website, phone number or both for the OAG’s office is to be included and that information is now available: https://illinoisattorneygeneral.gov/consumers/hcform.pdf and 1-877-305-5145.
Additional changes to the financial assistance application and process are outlined in prior memos. The OAG’s letter indicates hospitals will be allowed 90 days beyond January 1, 2022 to complete the changes to the financial assistance application.
Community Benefit Report Timing
The Illinois Community Benefits Act requires certain hospitals to file a report with the OAG six months after the hospital/system fiscal year end (FYE). Public Act 102-0581 requires new information to be part of the community benefits report as of January 1, 2022. The OAG’s letter now clarifies that hospitals with FYEs in 2021, but reports filed in 2022, do not need to include the new requirements. Hospitals with FYEs in 2022 and a portion of the fiscal year in 2021 need to include the new information for the period occurring between January 1, 2022 and the FYE.
The OAG has revised the community benefits report form and instructions but it is currently unknown when they will be posted on the OAG’s website. Contact us with any questions.