Required Changes to Hospital Financial Assistance and Community Benefits Reporting
August 26, 2021
MEMORANDUM
Three pieces of legislation passed earlier this year require hospitals to make changes to their financial assistance policies/applications and community benefit reporting, if applicable. IHA’s comprehensive summary can be found here and below are effective dates now that the Governor has signed them into law.
All hospitals licensed in Illinois are subject to the new requirements outlined below.
Effective October 24, 2021: Public Act 102-004. (House Bill 158). Section 15-5 amends the Fair Patient Billing Act regarding patient notifications. Currently, hospitals must make available information regarding financial assistance from the hospital in the form of either a brochure, an application for financial assistance, or other written material in the admissions and registration area. The emergency room is now an added location where this information needs to be made available. The law also allows this and other information to be made available electronically.
Effective December 1, 2021: Public Act 102-0504. (House Bill 3803). It also amends the Fair Patient Billing Act and requires hospitals to proactively offer information on charity care options available to uninsured patients, regardless of their immigration status or residency. This new requirement is effective on the first day of the first month following 90 days after becoming law, which is when the Governor signs it.
Effective January 1, 2022: Public Act 102-0581. (Senate Bill 1840). Section 10 amends the Hospital Uninsured Patient Discount Act:
- New definitions;
- Lowering of the threshold to $150 for medically necessary services in urban hospitals;
- Lowering of the maximum collectible amount to 20% of family income;
- Additional information on the financial assistance application related to race, ethnicity, sex, preferred language and complaints;
- Extension of the financial assistance application period to 90 days;
- Allowing a temporary visitor’s driver’s license to be used for residency verification; and
- Assisting uninsured patients who receive community-based primary care provided by an FQHC or free and charitable clinic and are referred by such to the hospital to apply for public health insurance programs or to apply for hospital financial assistance when hospital services are scheduled.
Further information on these provisions are in IHA’s summary.
Only hospitals subject to the Illinois Community Benefits Act are subject to the new requirements below. It does not impact investor-owned, government, small (less than 100 beds) or rural hospitals.
Effective January 1, 2022, unless otherwise noted: Public Act 102-0581 amends the Community Benefits Act:
- New definitions;
- Requires the community benefit plan to include activities the hospital is taking to address health equity, reduce disparities and improve community health;
- Public disclosure of their annual community benefit report (does not include audited financials);
- Additional information included:
- Charity cost by hospital if part of a system and a subset of charity costs provided in the emergency department;
- Net patient revenue by hospital;
- Financial assistance applications statistics including the five most frequent reasons for financial assistance denials; and
- To the extent that race, ethnicity, sex, or preferred language is collected and available for financial assistance applications, the statistics related to financial assistance applications shall be reported by race, ethnicity, sex, and preferred language. Public reporting of this information shall begin with the community benefit report filed on or after July 1, 2022.
Further information on these provisions are in IHA’s summary.
If you have questions, please contact IHA.