©2008 Office of Massachusetts Attorney General Martha Coakley Community Benefits Guidelines Office of Attorney General Martha Coakley February 23, 2009

Community Benefits History of Guidelines Non-profit, acute care hospitals – 1994 HMOs 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

Community Benefits Advisory Task Force Attorney General Coakley convened a Community Benefits Advisory Task Force in January, Members included hospital and HMO representatives, health care and consumer advocates, representatives from DPH, community health centers, and academia.

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

Community Benefits Accountability Transparency Process Pre-planning Community Involvement Statewide Priorities Streamlined Reporting Address Medical Debt Highlights of Revision

©2008 Office of Massachusetts Attorney General Martha Coakley 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 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

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

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

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

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

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

Community Benefits Report Process reporting- the process of developing the Plan Program reporting – detailed info on programs, including goals/measures Expenditure reporting

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

Optional Reporting Community service programs Bad debt – if hospital adopts recommended medical debt collection practices IRS Form 990 community benefit expenditures – for comparison Community Benefits

©2008 Office of Massachusetts Attorney General Martha Coakley 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

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

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