Financial Assistance Policies

California and other western states are increasingly imposing a maze of regulatory requirements on healthcare providers to offer free or discounted care, beyond the requirements of federal law.  Athene Law has helped dozens of hospitals, rural health clinics, federally qualified health centers and ambulance programs develop and implement financial assistance policies.  Athene Law has also supported hospitals respond to inquiries by the California he Department of Healthcare Access and Information (HCAI) regarding alleged failure to comply with state financial assistance policy and debt collection laws. 

Specific to hospitals, Athene Law has well versed in the intersection of the many authorities governing a hospital’s fair billing, financial assistance and debt collection policies, including 501(r) of the Internal Revenue Code, cost reporting rules (including Medicare bad debt), and Hospital Fair Pricing Program, as recently amended by AB 1020 (2022), SB 531 (2022), AB 2297 (2024) and SB 1061 (2024).

Capabilities

Clients in the healthcare industry, including physicians and groups, facilities, for-profit and non-profit entities, hospitals, and hospital systems need guidance and representation for a variety of needs.

Athene Law’s diverse experience within the healthcare industry has prepared the team to represent practices and professionals in a highly-regulated environment. 

Financial assistance policies capabilities include:

• Charity care and discount payment policy
• FQHC and RHC sliding scale policies
• Debt collection policy
• Discount payment applications
• Public postings and written notices
• Implementation issues with financial assistance policies
• Litigation arising from financial assistance denials
• HCAI reviews
• Responding to and challenging HCAI citations