Community Benefits Guidelines

1. Community BenefitsGuidelines Office of Attorney General Martha Coakley February 23, 2009 ©2008 Office of Massachusetts Attorney General Martha Coakley

2. 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

3. 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

4. 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

5. 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

6. 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

7. 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

8. 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

9. 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

10. 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

11. 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

12. 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

13. 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

14. 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

15. 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

16. 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

17. 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

18. 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