Client: Massachusetts Division of Health Care Finance and Policy, Health Safety Net (HSN)

HSN Compliance Reviews

Public Consulting Group (PCG) has been conducting financial reviews of the Health Safety Net (HSN) on behalf of the Division of Health Care Finance and Policy (DHCFP) annually each spring, beginning in 2010.  DHCFP requires that PCG review requested HSN fiscal years in order to confirm that the provider billed the HSN in compliance with HSN regulations and that the underlying financial records to support the claims are appropriate.  PCG’s reviews focus on the following areas:

  • Emergency Room Bad Debt Claiming (ERBD)
    • Demonstrated reasonable effort to collect payment
      • Was the facility’s approved collection policy followed? 
      • Are sufficient collection efforts documented (including letters, phone calls, etc.)?
      • Was there a balance greater than $1,000? If so, was a certified letter sent?
    • ERBD eligibility
      • Was the service emergent?
      • Was the patient uninsured, rather than insured or underinsured?
      • Was the ERBD filed a minimum of 120 days after the date or service
  • ERBD Recoveries
    • To determine if revenue received on ERBD accounts after write-off was properly reported to DHCFP
  • HSN Secondary Claims
    • To confirm that claims that were written-off with HSN as the secondary payer to Medicare were appropriate
  • Free Care Income
    • To determine if the facility receives endowment funds and if/how a portion of those endowments are properly allocated to offset HSN income

Review Results

In the spring of 2010, PCG conducted 20 hospital and five community health center (CHC) reviews for the claims periods of FY 2008 and 2009. In the spring of 2011, PCG conducted field reviews of nine hospitals and two CHCS for the claims period of FY 2010. In the spring of 2012, PCG conducted reviews of 12 hospitals and one CHC for the claims period of FY 2011. The average amount of funds recouped by the Commonwealth as a result of PCG reviews was $500,000 annually.