St. Patrick Hospital and Health Sciences Center

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Prompt Payment Discount Policy

Statutory/Regulatory Source:
OIG Special Fraud Alert regarding waiver of Medicare co-payments/deductibles and OIG Special Advisory Bulletin discusses “Offering Gifts and Other Inducements to Beneficiaries”.

Objective:
To define Providence Health & Services Washington/Montana Region (PH&S WA/MT) standards associated with offering prompt payment discounts for outpatient and inpatient hospital services provided to patients.

Purpose:
To treat insured and uninsured patients in a manner consistent with Providence’s Mission and Core Values. This policy is intended to work in tandem with applicable charity care and uninsured discount policies that provide for discounts or full write-offs of charges to qualified patients, regardless of such patient’s ability to pay.

Scope:
1. Limited to hospital services only.

Definitions:
Prompt Payment Discount Pecentage: A specified discount and partial write-off of co-payments, deductibles or percentage of amounts due from an individual patient to a hospital.

Services: for purposes of this policy, the term “services” shall include inpatient and outpatient hospital services.

Uninsured Discount: for purposes of this policy, the term “uninsured discount” shall mean partial write-off of amounts due Providence hospitals from uninsured patients for the provision of services. Uninsured discounts will not be applied to; court mandated payments, co-pay/deductibles, or any individual that resides outside of the United States and travel to the United States for the purpose of receiving services.

Uninsured: for purposes of this policy, the term “uninsured” shall mean those individuals without commercial, or government (including Medicare/Medicaid) health insurance.

Policy:
Each hospital will implement policies and procedures that provide for prompt payment discounts for inpatient and outpatient hospital services.

  1. Prompt Payment Discount Percentage: A prompt pay discount of ten percent (10%) will be
    offered by each acute care hospital for all patient groups.
  2. Applicability of the Policy: The prompt payment discount will be offered to all self-pay
    patients, including balance after insurance.
    1. The prompt payment discount will be offered in addition to the uninsured discount and any
      partial charity balances.
    2. The patient/guarantor must pay the account in full within thirty (30) days of the first billing
      statement to receive the prompt pay discount.
    3. Reference and language regarding the availability of a prompt pay discount will be on the first
      patient/guarantor self-pay statements.
    4. The timing of the discounts may be extended to patients who have substantial personal
      responsibility balances at the discretion of the Revenue Cycle Management Director or
      HSNW Director. The Director must properly document each instance of the prompt payment
      discount. Offering a higher level of discount (10%) is not allowed under any circumstances.
  3. Documentation: Each hospital and Health Services Northwest (Regional Business Office) will
    ensure that prompt payment discounts that are given are properly documented, including the
    process to confirm account balances status and eligibility for the discount.
  4. Restrictions on Advertising Prompt Payment Discounts: Communication of the prompt
    payment discount can be given by hospital or HSNW staffs to patients/guarantors, or can be
    included on patient billing statements or brochures. However, no hospital shall disclose/advertise
    such discounts in promotional materials or in any manner designed to target or attract Medicare
    beneficiaries or to generate business payable by Medicare/other federal health care programs to
    the Providence hospital.
  5. Applicability of Charity Care & Uninsured Discount Policies: This policy is intended to
    work in tandem with applicable charity care and uninsured discount policies based on
    patient/guarantor eligibility.
  6. Cost Reports: Each hospital will ensure that its cost report reflects full uniform charges (not
    discounted amounts) and will make its fiscal intermediary aware that it has reported its full charges on its cost report.
  7. Annual Review of Policy: This policy and the discount amount shall be reviewed annually
    by the Providence Washington/Montana Region’s CFO. The PH&S WA/MT Region CFO
    may propose revisions to this policy based on such reviews.

Procedure:
Payments received at the facility in which a prompt payment discount is applied, shall be recorded on the Cash Receipts Journal that is sent to HSNW. The entry must include the payment amount and the 10% discount amount.

CONSEQUENCES:

  • Violation or misuse of this policy may constitute grounds for immediate disciplinary action, up to and including termination of employment, service, or association with
    PH&S. Violation of the laws and regulations upon which this policy is based may result
    in possible civil and/or criminal action.
  • Knowledge of a violation or potential violation of this policy must be reported directly to the Regional Revenue Cycle Management Director for WA/MT. Failure to do so is considered a violation of policy and may lead to disciplinary action