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Community Benefits Guidelines . 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

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Community BenefitsGuidelines

Office of Attorney General Martha Coakley

February 23, 2009

©2008 Office of Massachusetts Attorney General Martha Coakley


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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

©2008 Office of Massachusetts Attorney General Martha Coakley


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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.

©2008 Office of Massachusetts Attorney General Martha Coakley


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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


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Accountability

Transparency

Process

Pre-planning

Community Involvement

Statewide Priorities

Streamlined Reporting

Address Medical Debt

Community Benefits

Highlights of Revision

©2008 Office of Massachusetts Attorney General Martha Coakley


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Community Benefits

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

©2008 Office of Massachusetts Attorney General Martha Coakley


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Community Benefits

Statewide Priorities

  • Supporting Health Care Reform

  • Chronic Disease Management

  • Reducing Health Disparities

  • Promoting Wellness of Vulnerable Populations

©2008 Office of Massachusetts Attorney General Martha Coakley


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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.

©2008 Office of Massachusetts Attorney General Martha Coakley


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Community Benefits

Leadership

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

©2008 Office of Massachusetts Attorney General Martha Coakley


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Community Benefits

Community Involvement

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

©2008 Office of Massachusetts Attorney General Martha Coakley


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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.

©2008 Office of Massachusetts Attorney General Martha Coakley


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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”

©2008 Office of Massachusetts Attorney General Martha Coakley


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Community Benefits

Report

  • Process reporting- the process of developing the Plan

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

  • Expenditure reporting

©2008 Office of Massachusetts Attorney General Martha Coakley


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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

©2008 Office of Massachusetts Attorney General Martha Coakley


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Community Benefits

Optional Reporting

  • Community service programs

  • Bad debt – if hospital adopts recommended medical debt collection practices

  • IRS Form 990 community benefit expenditures – for comparison

©2008 Office of Massachusetts Attorney General Martha Coakley


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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

©2008 Office of Massachusetts Attorney General Martha Coakley


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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

©2008 Office of Massachusetts Attorney General Martha Coakley


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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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