SUPPLEMENTAL INFORMATION 1
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SCHEDULE H, PART VI: INTEGRIS AMBULATORY CARE CORPORATION (IACC) IS A MEMBER OF AN INTEGRATED HEALTHCARE DELIVERY SYSTEM (INTEGRIS HEALTH SYSTEM OR SYSTEM) CONTROLLED BY INTEGRIS HEALTH, INC. AS SUCH IACC FOLLOWS CERTAIN POLICIES AND PROCEDURES ESTABLISHED AT THE SYSTEM LEVEL, MANY OF WHICH ARE DESCRIBED BELOW. IACC DOES NOT HAVE A DIRECTLY OWNED HOSPITAL FACILITY, BUT OWNS A MINORITY INTEREST IN FOUR HOSPITAL FACILITIES, OKLAHOMA CENTER FOR ORTHOPAEDIC & MULTI-SPECIALTY SURGERY (OCOM), THROUGH ITS INVESTMENT IN SOUTHWEST AMBULATORY SURGERY CENTER, LLC, COMMUNITY HOSPITAL AND TPG HOSPITAL (D/B/A NW SURGICAL HOSPITAL (HPI FACILITIES), THROUGH ITS INVESTMENT IN HPI AND LAKESIDE WOMEN'S HOSPITAL, LLC (LWH). THE ACTIVITY REPORTED ON SCHEDULE H, PARTS I-III INCLUDES THE ACTIVITY OF OCOM, HPI FACILITIES & LWH AS WELL AS THE THE DIRECT ACTIVITY OF IACC AND IACC'S PROPORTIONATE SHARE OF THE ACTIVITY OF THE NON-HOSPITAL JOINT VENTURES LISTED ON SCHEDULE H, PART V, SECTION D.
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SUPPLEMENTAL INFORMATION 2
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REPORTING GROUP B PART VI, LINE 3C: CRITERIA USED FOR DETERMINING ELIGIBILITY FOR FREE OR DISCOUNTED CARE BASED ON A PATIENT'S REQUEST FOR FINANCIAL ASSISTANCE - A WRITTEN REQUEST FOR FINANCIAL ASSISTANCE BASED UPON THE INDIVIDUAL'S CURRENT FINANCIAL NEED. THE REQUEST SHOULD BE IN WRITING FROM THE PATIENT AND THE AMOUNT OF FINANCIAL AID GRANTED SHOULD BE DOCUMENTED BY THE CEO OR CFO. THE REQUEST CAN BE ACCEPTED BEFORE OR AFTER SURGERY. REPORTING GROUP A PART I, LINE 6A: INTEGRIS HEALTH, INC., (EIN: 73-1192764), THE PARENT ORGANIZATION OF INTEGRIS AMBULATORY CARE CORPORATION, PRODUCES A CONSOLIDATED COMMUNITY BENEFIT REPORT THAT IS MADE AVAILABLE TO THE PUBLIC. BENEFIT REPORT THAT IS MADE AVAILABLE TO THE PUBLIC. BENEFIT REPORT THAT IS MADE AVAILABLE TO THE PUBLIC.
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SUPPLEMENTAL INFORMATION 3
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REPORTING GROUP A PART I, LINE 7: COSTING METHODOLOGY: THE RATIO OF PATIENT CARE COST TO CHARGES IS APPLIED TO THE CHARITY ATTRIBUTABLE TO PATIENT ACCOUNTS TO CALCULATE THE ESTIMATED COST OF CHARITY ATTRIBUTABLE TO PATIENT ACCOUNTS THAT IS REPORTED ON PART 1, LINE 7. DISCOUNTS AND PAYMENTS ON PATIENT ACCOUNTS ARE RECORDED AS AN ADJUSTMENT TO REVENUE, NOT BAD DEBT EXPENSE. REPORTING GROUP B PART I, LINE 7: COSTING METHODOLOGY: THE COST TO CHARGE RATIO CALCULATED IN OCOM'S 2018 COST REPORT WAS USED.
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SUPPLEMENTAL INFORMATION 4
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REPORTING GROUP A PART II: COMMUNITY BUILDING ACTIVITIES COMMUNITY-BUILDING ACTIVITIES IMPROVE THE COMMUNITY'S HEALTH AND SAFETY BY ADDRESSING THE ROOT CAUSE OF HEALTH PROBLEMS, SUCH AS POVERTY, HOMELESSNESS, AND ENVIRONMENTAL HAZARDS. THESE ACTIVITIES STRENGTHEN THE COMMUNITY'S CAPACITY TO PROMOTE THE HEALTH AND WELL-BEING OF ITS RESIDENTS BY OFFERING THE EXPERTISE AND RESOURCES OF THE HEALTH CARE ORGANIZATION. COSTS FOR THESE ACTIVITIES INCLUDE CASH AND IN-KIND DONATIONS AND EXPENSES FOR THE DEVELOPMENT OF A VARIETY OF COMMUNITY-BUILDING PROGRAMS AND PARTNERSHIPS.
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SUPPLEMENTAL INFORMATION 5
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REPORTING GROUP A PART III, LINES 2, 3 AND 4: EFFECTIVE JULY 1, 2018, INTEGRIS HEALTH ADOPTED THE NEW REVENUE RECOGNITION STANDARD, ACCOUNTING STANDARDS UPDATE (ASU) 2014-09, REVENUE FROM CONTRACTS WITH CUSTOMERS (TOPIC 606), ISSUED BY THE FASB IN 2014, USING THE MODIFIED RETROSPECTIVE METHOD. WITH THE ADOPTION OF THE NEW REVENUE RECOGNITION STANDARD, NET PATIENT SERVICE REVENUE IS REPORTED AT THE AMOUNT THAT REFLECTS THE CONSIDERATION TO WHICH INTEGRIS HEALTH EXPECTS TO BE ENTITLED IN EXCHANGE FOR PROVIDING PATIENT CARE HEALTHCARE SERVICES PROMISED IN THE CONTRACT WITH A PATIENT REPRESENT A BUNDLE OF GOODS AND (OR) SERVICES THAT IS DISTINCT AND ACCOUNTED FOR AS A SINGLE PERFORMANCE OBLIGATION. THE TRANSACTION PRICE FOR THE BUNDLED GOODS AND (OR) SERVICES PROVIDED IS ESTIMATED BY REDUCING THE TOTAL STANDARD CHARGES BY VARIABLE PRICE CONCESSIONS, INCLUDING CONTRACTUAL ADJUSTMENTS BASED ON THE TERMS PROVIDED BY (IN THE CASE OF MEDICARE AND MEDICAID) OR NEGOTIATED WITH (IN THE CASE OF MANAGED CARE AND COMMERCIAL INSURANCE COMPANIES) THIRD-PARTY PAYORS, INTEGRIS HEALTH DISCOUNT POLICIES, AND OTHER IMPLICIT PRICE CONCESSIONS BASED ON HISTORICAL COLLECTIONS EXPERIENCE FOR UNINSURED AND UNDER-INSURED PATIENTS WHO DO NOT QUALIFY FOR FINANCIAL ASSISTANCE. A PORTFOLIO APPROACH BY MAJOR PAYOR CATEGORIES AND TYPES OF SERVICE WAS USED TO ESTIMATE THE HISTORICAL COLLECTIONS EXPERIENCE. SUBSEQUENT CHANGES TO THE ESTIMATE OF THE TRANSACTION PRICE ARE GENERALLY RECORDED AS ADJUSTMENTS TO NET PATIENT SERVICE REVENUE IN THE PERIOD OF THE CHANGE. PORTFOLIO COLLECTION ESTIMATES ARE UPDATED AT LEAST QUARTERLY BASED ON ACTUAL COLLECTIONS EXPERIENCE. INTEGRIS HEALTH BELIEVES THAT REVENUE RECOGNIZED BY UTILIZING THE PORTFOLIO APPROACH APPROXIMATES THE REVENUE THAT WOULD HAVE BEEN RECOGNIZED IF AN INDIVIDUAL CONTRACT APPROACH WAS USED. SUBSEQUENT CHANGES THAT ARE DETERMINED TO BE THE RESULT OF AN ADVERSE CHANGE IN THE PATIENT'S ABILITY TO PAY ARE RECORDED AS BAD DEBT EXPENSE. REVENUE RELATED TO PROVIDING CARE TO PATIENTS IS RECOGNIZED AS THE PERFORMANCE OBLIGATION IS SATISFIED OVER THE PERIOD OF TIME THE PATIENT IS RECEIVING TREATMENT, AS THE PATIENT IS SIMULTANEOUSLY RECEIVING AND CONSUMING THE BENEFITS PROVIDED BY INTEGRIS HEALTH. THE PERFORMANCE OBLIGATION IS GENERALLY SATISFIED OVER AN AVERAGE PERIOD OF LESS THAN FIVE DAYS FOR INPATIENT SERVICES AND ONE DAY FOR OUTPATIENT SERVICES. GENERALLY, PATIENTS AND THIRD-PARTY PAYORS ARE BILLED WITHIN DAYS AFTER THE SERVICES ARE PERFORMED AND (OR) THE PATIENT IS DISCHARGED. THE TRANSACTION PRICE RELATED TO UNSATISFIED OR PARTIALLY UNSATISFIED PERFORMANCE OBLIGATIONS AT THE END OF THE REPORTING PERIOD PRIMARILY RELATE TO INPATIENT ACUTE CARE SERVICES FOR PATIENTS WHO REMAIN ADMITTED AT THAT TIME. THESE CONTRACT ASSETS WERE $27,808,650 ON JULY 1, 2018 AT THE ADOPTION OF THE NEW REVENUE RECOGNITION STANDARD. AS OF JUNE 30, 2019, CONTRACT ASSETS OF $26,658,106 WERE RECORDED IN PATIENT ACCOUNTS RECEIVABLE ON THE CONSOLIDATED BALANCE SHEETS. PATIENT ACCOUNTS RECEIVABLE IS REPORTED AT THE AMOUNT THAT REFLECTS THE CONSIDERATION TO WHICH INTEGRIS HEALTH EXPECTS TO BE ENTITLED IN EXCHANGE FOR PROVIDING PATIENT CARE. THE PRIMARY COLLECTION RISKS RELATE TO UNINSURED PATIENT ACCOUNTS, INCLUDING PATIENT ACCOUNTS FOR WHICH THE PRIMARY INSURANCE COMPANY HAS PAID THE AMOUNTS COVERED BY THE APPLICABLE AGREEMENT, BUT PATIENT RESPONSIBILITY AMOUNTS REMAIN OUTSTANDING. IMPLICIT PRICE CONCESSIONS RELATE PRIMARILY TO AMOUNTS DUE DIRECTLY FROM PATIENTS BASED UPON MANAGEMENT'S ASSESSMENT OF HISTORICAL WRITE-OFFS AND EXPECTED NET COLLECTIONS CONSIDERING BUSINESS AND ECONOMIC CONDITIONS, TRENDS IN HEALTH CARE COVERAGE, AND OTHER COLLECTION INDICATORS. PATIENT ACCOUNTS ARE MONITORED AND, IF NECESSARY, PAST DUE ACCOUNTS ARE PLACED WITH COLLECTION AGENCIES IN ACCORDANCE WITH GUIDELINES ESTABLISHED BY MANAGEMENT. ACCOUNTS ARE WRITTEN OFF WHEN ALL REASONABLE INTERNAL AND EXTERNAL COLLECTION EFFORTS HAVE BEEN PERFORMED. ESTIMATED IMPLICIT PRICE CONCESSIONS OF $185,580,000 WERE RECORDED AS REDUCTIONS TO PATIENT ACCOUNTS RECEIVABLE AT JUNE 30, 2019 ON THE CONSOLIDATED BALANCE SHEETS. REPORTING GROUP B: PART III, lINE 2: THE METHODOLOGY USED TO CALCULATE THE ORGANIZATION'S BAD DEBT EXPENSE IS AS FOLLOWS: -75% OF ACCOUNTS RECEIVABLE NET OF THE CONTRACTUAL ALLOWANCE AGED 120 DAYS OR GREATER (EXCLUDING LEGAL LIABILITY), PLUS 25% OF ACCOUNTS RECEIVABLE NET OF THE CONTRACTUAL ALLOWANCE IN THE 90 DAY BUCKET. WE RESERVE 50% OF LEGAL LIABILITY OVER 120 DAYS. -AN ADDITIONAL RESERVE IS APPLIED ON TOP OF THE RESERVE ABOVE FOR SELF-PAY PATIENTS BASED ON HISTORICAL PAYMENT TRENDS. REPORTING GROUP B PART III, LINE 3: METHODOLOGY USED BY THE ORGANIZATION TO ESTIMATE THE ORGANIZATION'S BAD DEBT EXPENSE ATTRIBUTABLE TO PATIENTS ELIGIBLE UNDER THE FAP THE HOSPITAL CLASSIFIES FINANCIAL ASSISTANCE AS A CONTRACTUAL WRITE OFF AND NOT AS BAD DEBT, AND DOES NOT ATTRIBUTE ANY PORTION OF ITS BAD DEBT REPORTED ON PART III, LINE 2 TO PATIENTS ELIGIBLE FOR FINANCIAL ASSISTANCE UNDER ITS CHARITY POLICY. REPORTING GROUP B PART III, LINE 4: FOOTNOTE TO THE ORGANIZATION'S FINANCIAL STATEMENTS THAT DESCRIBES BAD DEBT EXPENSE OCOM DOES NOT HAVE A STAND-ALONE AUDIT AND IS INCLUDED IN THE CONSOLIDATED FINANCIALS OF INTEGRIS AMBULATORY CARE CORP. OCOM ACCOUNTS FOR BAD DEBT EXPENSE AS FOLLOWS: -75% OF ACCOUNTS RECEIVABLE NET OF THE CONTRACTUAL ALLOWANCE AGED 120 DAYS OR GREATER (EXCLUDING LEGAL LIABILITY), PLUS 25% OF ACCOUNTS RECEIVABLE NET OF THE CONTRACTUAL ALLOWANCE IN THE 90 DAY BUCKET. WE RESERVE 50% OF LEGAL LIABILITY OVER 120 DAYS. -AN ADDITIONAL RESERVE IS APPLIED ON TOP OF THE RESERVE ABOVE FOR SELF-PAY PATIENTS BASED ON HISTORICAL PAYMENT TRENDS.
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SUPPLEMENTAL INFORMATION 6
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REPORTING GROUP A PART III, LINE 8: THE AMOUNTS REPORTED ON PART III, LINES 5 AND 6 REPRESENT INTEGRIS AMBULATORY CARE CORPORATION'S (IACC) PROPORTIONATE SHARE OF THE ALLOWABLE COSTS AND MEDICARE REIMBURSMENTS THAT ARE REPORTED ON OKLAHOMA CENTER FOR ORTHOPAEDIC & MULTI-SPECIALTY SURGERY'S (OCOM) MEDICARE COST REPORT & LAKESIDE WOMEN'S HOSPITAL LLC (LWH) MEDICARE COST REPORT. COSTING METHODOLOGY: MEDICARE ALLOWABLE COSTS WERE CALCULATED USING A COST-TO-CHARGE RATIO AND THE MEDICARE FILED COST REPORT. REPORTING GROUP B PART III, LINE 8: THE COST TO CHARGE METHODOLOGY WAS USED IN ORDER TO CALCULATE THE MEDICARE ALLOWABLE COSTS RELATED TO PAYMENTS RECEIVED FROM MEDICARE. ANY RESULTING SHORTFALL IS NOT TREATED AS A COMMUNITY BENEFIT.
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SUPPLEMENTAL INFORMATION 7
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REPORTING GROUP A PART III, LINE 9B: PATIENTS MAY, AT ANY TIME DURING THE COLLECTION CYCLE, SUBMIT FINANCIAL INFORMATION FOR FINANCIAL ASSISTANCE OR CHARITY CONSIDERATION PURSUANT TO INTEGRIS POLICY SYS-RCM-100 CHARITY SERVICES. ALL AVAILABLE AVENUES OF ASSISTANCE AND AVAILABLE PAYMENTS FROM THIRD PARTY PAYORS MUST BE EXHAUSTED BEFORE SUCH ASSISTANCE FOR CHARITY OR OTHER FINANCIAL ASSISTANCE IS CONSIDERED. IACC DOES NOT PURSUE COLLECTION OF AMOUNTS DETERMINED TO QUALIFY AS CHARITY CARE.
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SUPPLEMENTAL INFORMATION 8
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REPORTING GROUP A PART VI, LINE 2: NEEDS ASSESSMENT INTEGRIS HEALTH UTILIZES A VARIETY OF TOOLS TO DETERMINE THE HEALTH CARE NEEDS OF OUR COMMUNITIES. THESE INCLUDE PARTNERSHIPS WITH LOCAL COMMUNITY AGENCIES AND ORGANIZATIONS TO DETERMINE SPECIFIC TARGET MARKET NEEDS, PROGRAM SURVEYS AND COMMUNITY FOCUS GROUPS, PROGRAM EVALUATIONS FROM PARTICIPANTS IN OUR COMMUNITY HEALTH SCREENINGS, HEALTH EDUCATION AND SUPPORT GROUPS, THE COUNTY HEALTH RANKINGS REPORT AND THE OKLAHOMA STATE HEALTH DEPARTMENT'S "STATE OF THE STATE HEALTH REPORT." AFTER REVIEWING THESE MATERIALS FOR ISSUES CONCERNING ACCESS TO CARE, HEALTH EDUCATION NEEDS AND GAPS IN SERVICES IN OUR COMMUNITIES, INTEGRIS HEALTH DETERMINES HOW TO ADDRESS THESE ISSUES BY DEVELOPING PROGRAMS/SERVICES TO IMPLEMENT, INCLUDING, BUT NOT LIMITED TO, HEALTH SCREENINGS, COMMUNITY HEALTH EDUCATION AND WELLNESS PROGRAMS, SUPPORT GROUPS, AND ACCESS TO HEALTH CARE FACILITIES. INTEGRIS HEALTH UTILIZES OUR HEALTH SYSTEM RESOURCES, FACILITIES AND PERSONNEL FOR MANY OF THESE PROGRAMS, BUT ALSO PARTNERS WITH OUR COMMUNITIES AND DEVELOPS COLLABORATIONS WITH LOCAL NON-PROFIT AGENCIES, CIVIC ORGANIZATIONS, SCHOOLS, AND CHURCHES TO IMPROVE THE ISSUES IDENTIFIED. REPORTING GROUP B PART VI, LINE 2: NEEDS ASSESSMENT OKLAHOMA CENTER FOR ORTHOPAEDIC AND MULTI-SPECIALTY SURGERY, LLC (OCOM) WAS RESTRUCTURED EFFECTIVE NOVEMBER 1, 2018 WHEN A NEW JOINT VENTURE WAS FORMED BETWEEN INTEGRIS AMBULATORY CARE CORPORATION (INTEGRIS), AN OKLAHOMA NOT FOR PROFIT CORPORATION THAT IS TAX-EXEMPT UNDER SECTION 501(C)(3), AND USP OKLAHOMA, INC. (USP OK), AN OKLAHOMA FOR PROFIT CORPORATION THAT IS AN AFFILIATE OF UNITED SURGICAL PARTNERS. THIS JOINT VENTURE OPERATED THE OCOM FACILITY DURING THE TAX YEAR. THE JOINT VENTURE IS A PARTNERSHIP FOR WHICH A FORM 1065 IS FILED. HOWEVER, WHEN THE NEW JOINT VENTURE WAS FORMED WITH INTEGRIS, OCOM BECAME SUBJECT TO THE 501(R) PROVISIONS. REPORTING GROUP C PART VI, LINE 2: NEEDS ASSESSMENT HEALTH VENTURES IS A PARTNERSHIP FORMED IN FY2019 BETWEEN IACC, AN OKLAHOMA NOT FOR PROFIT CORPORATION THAT IS TAX-EXEMPT UNDER SECTION 501(C)(3) AND USP OKLAHOMA, INC. (USP), AN UNRELATED OKLAHOMA FOR PROFIT CORPORATION FOR THE PURPOSE OF ACQUIRING OWNERSHIP IN OR DEVELOPLING FREESTANDING AMBULATORY SURGERY HOSPITALS. ON NOVEMBER 1, 2018, HEALTH VENTURES ACQUIRED 51% OF HPI HOLDINGS, LLC (HPI). HPI OWNS A 100% INTEREST IN COMMUNITY HOSPITAL, LLC AND TPG HOSPITAL, LLC. THIS JOINT VENTURE OPERATED THE COMMUNITY HOSPITAL AND TPG HOSPITAL FACILITIES DURING THE TAX YEAR. THE JOINT VENTURE IS A PARTNERSHIP FOR WHICH A FORM 1065 IS FILED. HOWEVER, WHEN HPI WAS ACQUIRED BY HEALTH VENTURES, COMMUNITY HOSPITAL AND TPG HOSPITAL BECAME SUBJECT TO THE 501(R) PROVISIONS.
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SUPPLEMENTAL INFORMATION 9
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REPORTING GROUP A PART VI, LINE 3: PATIENT EDUCATION - ELIGIBILITY FOR ASSISTANCE INTEGRIS HEALTH USES A MULTI-FACETED APPROACH TO EDUCATE OUR PATIENTS ON THE AVAILABILITY OF CHARITY AS WELL AS STATE AND FEDERAL FINANCIAL ASSISTANCE. THIS INCLUDES: *POSTERS CLEARLY DISPLAYED IN EVERY PATIENT REGISTRATION AREA SPEAKING TO OUR FINANCIAL ASSISTANCE PROGRAMS. *A FINANCIAL RIGHTS AND RESPONSIBILITY BROCHURE GIVEN TO EVERY PATIENT AT THE TIME OF THEIR REGISTRATION WHICH PROVIDES FINANCIAL ASSISTANCE PROGRAM DETAILS. *A CLEARLY MARKED PRESENCE ON THE INTEGRIS HEALTH ON-LINE BUSINESS OFFICE WEBSITE WITH A SECTION DEVOTED TO FINANCIAL ASSISTANCE PROGRAM DETAILS AS WELL AS AN ON-LINE CHARITY APPLICATION. *A DESCRIPTION OF THE FINANCIAL ASSISTANCE PROGRAM AS WELL AS THE APPLICATION PROCESS IS INCLUDED ON EVERY PATIENT BILL. FINANCIAL COUNSELORS MEET WITH PATIENTS TO IDENTIFY ELIGIBILITY FOR FEDERAL AND STATE ASSISTANCE PROGRAMS. REPORTING GROUP B PART VI, LINE 3: PATIENT EDUCATION - ELIGIBILITY FOR ASSISTANCE OCOM PATIENTS WERE INFORMED AND EDUCATED OVER THE PHONE OR IN PERSON PRIOR TO OR POST PROCEDURE ABOUT THE AVAILABILITY AND ELIGIBILITY OF FINANCIAL ASSISTANCE. REPORTING GROUP C PART VI, LINE 3: PATIENT EDUCATION - ELIGIBILITY FOR ASSISTANCE HPI FACILITY PATIENTS WERE INFORMED AND EDUCATED ONLINE, BY TELEPHONE, BY MAIL, ON POSTED SIGNS AND PAPER COPIES OR BROCHURES LOCATED IN ALL REGISTRATION AREAS THROUGHOUT THE FACILITIES, IN PERSON, AND IN BILLING STATEMENTS ABOUT THE AVAILABILITY AND ELIGIBILITY OF FINANCIAL ASSISTANCE.EGISTRATION STAFF REFERS PATIENTS TO WEBSITE AND TO THE BILLING DEPARTMENT AS NEEDED OR REQUESTED. THEY PRINT OFF CHARITY APPLICATIONS AND ASSISTS PATIENTS IN COMPLETING. IF TRANSLATION IS NEEDED TO HELP COMPLETE FORMS A CALL IS MADE INTO THE LANGUAGE LINE FOR ASSISTANCE. IF FINANCIAL NEED IS DETERMINED WHEN PATIENT IS IN PERSON AT FACILITY, EXAMPLE LACK OF INSURANCE OR UNABLE TO PAY, PATIENT IS ASSISTED WITH APPLICATION AND/OR REFERRED TO BILLING TO ASSIST. SCHEDULING, FINANCIAL COUNSELOR, REGISTRATION, AND AUTHORIZATION DEPARTMENT, REFER PATIENTS IN NEED OF ASSISTANCE TO WEBSITE AND TO BILLING AS NEEDED.
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SUPPLEMENTAL INFORMATION 10
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REPORTING GROUP A PART VI, LINE 4: COMMUNITY INFORMATION INTEGRIS HEALTH SYSTEM IS THE STATE'S LARGEST OKLAHOMA-OWNED HEALTH CARE SYSTEM AND ONE OF THE STATE'S LARGEST PRIVATE EMPLOYERS, WITH HOSPITALS, REHABILITATION CENTERS, PHYSICIAN'S CLINICS, MENTAL HEALTH FACILITIES, CANCER CENTERS, INDEPENDENT LIVING CENTERS, AND HOME HEALTH AGENCIES THROUGHOUT MOST OF THE STATE. ALL COUNTIES IN WHICH INTEGRIS HEALTH OPERATES INCLUDE ONE OR MORE FEDERALLY-DESIGNATED MEDICALLY UNDERSERVED AREAS OR POPULATIONS. INTEGRIS AMBULATORY CARE CORPORATION (IACC) IS LOCATED IN OKLAHOMA CITY, WHICH IS IN OKLAHOMA COUNTY IN CENTRAL OKLAHOMA. REPORTING GROUP B PART VI, LINE 4: COMMUNITY INFORMATION OCOM IS LOCATED IN SOUTH OKLAHOMA CITY WITH AN HOPD LOCATION (OCOM NORTH) IN NORTHWEST OKLAHOMA CITY AND THREE FREESTANDING IMAGING FACILITIES TO SERVICE OKLAHOMA CITY, IN OKLAHOMA COUNTY, OKLAHOMA. OKLAHOMA CITY IS THE COUNTY SEAT AND THE LARGEST CITY IN THE STATE. THERE ARE 20 CITIES AND SMALL TOWNS LOCATED IN THE COUNTY. THE ECONOMY SPECIALIZES IN OIL, GAS, QUARRYING, EXTRACTION, MANAGEMENT OF COMPANIES AND ENTERPRISES, AND PUBLIC ADMINISTRATION. ACCORDING TO THE 2016 POPULATION ESTIMATES, THE POPULATION OF OKLAHOMA COUNTY WAS 770,101. THE MEDIAN AGE FOR OKLAHOMA COUNTY IS 34.3 YEARS WHILE THE MEDIAN AGE FOR THE STATE OF OKLAHOMA IS 36.2 YEARS. THERE ARE 16.3% OF PERSONS IN POVERTY FOR BOTH OKLAHOMA COUNTY AND THE STATE OF OKLAHOMA. THE OKLAHOMA MEDIAN HOUSEHOLD INCOME IS $48,987 COMPARED TO $48,038 FOR THE STATE OF OKLAHOMA. THE MAJORITY OF RESIDENTS IN OKLAHOMA COUNTY IDENTIFY AS WHITE-NON-HISPANIC. THE NEXT LARGEST RACES/ETHNICITIES IN OKLAHOMA COUNTY ARE THE AFRICAN AMERICAN AND AMERICAN INDIAN/ALASKAN NATIVE POPULATIONS AT 16% AND 7% RESPECTIVELY (U.S. CENSUS BUREAU 2012-2016, AMERICAN COMMUNITY SURVEY, 5 -YEAR ESTIMATES). AVERAGE LIFE EXPECTANCY VARIES WIDELY THROUGHOUT OKLAHOMA COUNTY. IN THE 73131 ZIP CODE, CITIZENS HAVE AN OVERALL LIFE EXPECTANCY OF ALMOST 83 YEARS. FURTHER SOUTH IN THE 73145 ZIP CODE, RESIDENTS HAVE AN OVERALL LIFE EXPECTANCY OF 64 YEARS. DURING 2012-2016, THE PERCENT OF STUDENTS RECEIVING THEIR HIGH SCHOOL DIPLOMA IN OKLAHOMA COUNTY WAS 86.4% WHICH WAS SLIGHTLY LOWER THAT THE STATE AT 87.3%. HOWEVER, OKLAHOMA COUNTY HAD A HIGHER PERCENTAGE OF RESIDENTS WITH A BACHELOR OR ADVANCED DEGREE (30.8%) THAN THE STATE (24.5%) DURING THIS SAME PERIOD. DURING 2012-2016, 15.8% OF PERSONS UNDER THE AGE OF 65 IN OKLAHOMA COUNTY WERE WITHOUT HEALTH INSURANCE, WHICH WAS SLIGHTLY LOWER THAN THE STATE AT 16.1%. IN 2016, 9.5% OF PERSONS UNDER THE AGE OF 18 IN OKLAHOMA COUNTY WERE WITHOUT HEALTH INSURANCE, COMPARED TO 8% OF PERSONS IN THE STATE OF OKLAHOMA WHO WERE WITHOUT HEALTH INSURANCE. ACCORDING TO THE OKLAHOMA HEALTH CARE AUTHORITY, 795,577 OF PERSONS IN THE STATE OF OKLAHOMA WERE ENROLLED IN MEDICAID OF WHICH 166,505 OF THOSE ENROLLED WERE IN OKLAHOMA COUNTY, (2018). MEDICARE ENROLLMENT IN THE STATE OF OKLAHOMA IN 2018 WAS APPROXIMATELY 578,271, ACCORDING TO THE CENTER FOR MEDICARE AND MEDICAID SERVICES, OF WHICH 124,591 ENROLLED WERE IN OKLAHOMA COUNTY. OCOM SOUTH IS LOCATED IN SOUTH OKLAHOMA CITY, NEAR INTEGRIS SOUTHWEST AND PROVIDES CARE TO THE CITIZENS OF SOUTH OKLAHOMA CITY AND SURROUNDING AREAS. OCOM SOUTH RECEIVED A CERTIFICATE OF DISTINCTION FROM THE JOINT COMMISSION IN APRIL 2019 FOR OUR TOTAL JOINT REPLACEMENT FOR BOTH HIPS AND KNEES.
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SUPPLEMENTAL INFORMATION 11
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REPORTING GROUP A PART VI, LINE 5: PROMOTION OF COMMUNITY HEALTH EVIDENCE OF THE ORGANIZATIONS' RESPONSIVENESS TO THE COMMUNITY, INCLUDING OPPORTUNITIES FOR COMMUNITY INVOLVEMENT IN GOVERNANCE AND ADVISORY GROUPS. IACC'S BOARD OF DIRECTORS IS APPOINTED BY INTEGRIS HEALTH, INC. INTEGRIS HEALTH, INC. IS GOVERNED BY A BOARD OF DIRECTORS SPECIFICALLY MADE UP OF MEN AND WOMEN WHO LIVE AND WORK IN THE COMMUNITY INCLUDING: LOCAL BUSINESS OWNERS, CIVIC LEADERS, COMMUNITY VOLUNTEERS, REPRESENTATIVES WORKING IN HIGHER EDUCATION, UTILITY COMPANIES, AND A VARIETY OF NON-PROFIT ORGANIZATIONS. PATIENT AND COMMUNITY ADVISORY GROUPS HAVE ALSO BEEN ESTABLISHED AT SEVERAL INTEGRIS FACILITIES ACROSS THE STATE. THESE GROUPS GIVE HOSPITAL LEADERS INPUT, SUGGESTIONS, AND FEEDBACK ON WAYS TO IMPROVE PROGRAMS, SERVICES, COMMUNITY NEEDS, AND PROCESS IMPROVEMENT IN CLINICAL AREAS. PROGRAMS ESTABLISHED TO MEET COMMUNITY NEEDS INCLUDE A FALLS PREVENTION PROGRAM FOR SENIOR CITIZENS, COMMUNITY HEALTH SCREENINGS AND PHYSICIAN LECTURES REQUESTED BY LOCAL SCHOOLS, CHURCHES, CIVIC GROUPS, AND COMMUNITY LEADERS TO ADDRESS SPECIFIC HEALTH ISSUES WHICH INCLUDE: DIABETES, CANCER DIAGNOSIS AND TREATMENT OPTIONS, OBESITY AND PHYSICAL FITNESS PROGRAMS, MEN'S UROLOGICAL HEALTH PROGRAMS AND PROSTATE SCREENINGS, CANCER SCREENINGS, SPANISH DIABETES SUPPORT GROUP, AFRICAN AMERICAN MEN AND WOMEN'S HEART HEALTH, AND STROKE LECTURES. ADVOCACY INITIATIVES FOR PROMOTING COMMUNITY-WIDE, STATE OR NATIONAL EFFORTS TO IMPROVE HEALTH OF THE POPULATION AND INCREASE ACCESS. INTEGRIS HEALTH PARTNERS WITH THE OKLAHOMA LIONS CLUB MOBILE HEALTH UNIT, THE OKLAHOMA STATE HEALTH DEPARTMENT, AND THE OKLAHOMA TURNING POINT PROGRAM TO INCREASE HEALTH SCREENING OPPORTUNITIES AND HEALTH ACCESS FOR PEOPLE LIVING IN RURAL, UNDERSERVED AREAS OF OKLAHOMA. THE PARTNERSHIP INCLUDES DONATION OF RESOURCES AND MONEY TO SPONSOR THE OPERATION OF THE LIONS MOBILE HEALTH UNIT WHICH TRAVELS AROUND THE STATE OFFERING FREE HEALTH SCREENINGS AND MEDICAL INFORMATION. THE OKLAHOMA STATE HEALTH DEPARTMENT AND THE OKLAHOMA TURNING POINT PROGRAM ASSIST WITH HEALTH SCREENINGS AND HELP WITH REFERRALS TO MEDICAL HOMES AND CLINICS FOR PEOPLE WITHOUT A PHYSICIAN AND FOR THOSE UNINSURED OR UNDERINSURED. INTEGRIS HEALTH PARTNERS WITH THE OKLAHOMA TURNING POINT PROGRAM, LOCAL CIVIC GROUPS, SUCH AS OUR CHAMBERS OF COMMERCE, ROTARY, AND KIWANIS CLUBS, TECHNOLOGY SCHOOLS, COMMUNITY COLLEGES, CHURCHES, AND LOCAL SCHOOLS IN A VARIETY OF EVENTS AND PROGRAMS TO EDUCATE THE COMMUNITY ON HEALTH/WELLNESS ISSUES, CREATE OPPORTUNITIES FOR HEALTH ACCESS, PROVIDE COMMUNITY SCREENINGS IN UNDERSERVED AREAS OF OKLAHOMA, AND TO GIVE STUDENTS AND COMMUNITY MEMBERS THE OPPORTUNITY TO VOLUNTEER FOR THESE EVENTS. THIS INCLUDES MEDICAL STUDENTS WHO WORK WITH INTEGRIS ACROSS THE STATE AT OUR EVENTS TO LEARN MORE ABOUT PROVIDING HEALTH SERVICES TO THE COMMUNITY AND TO HELP TRAIN THEM FOR FUTURE WORK IN THE HEALTHCARE ARENA. THE HOSPITAL'S ROLE IN WORKING WITH OTHERS TO IDENTIFY COMMUNITY NEEDS AND ADDRESS COMMUNITY PROBLEMS. INTEGRIS HEALTH WORKS WITH THE OKLAHOMA HOSPITAL ASSOCIATION, THE OKLAHOMA STATE MEDICAL ASSOCIATION, THE ALLIANCE FOR THE UNINSURED, THE OKLAHOMA STATE HEALTH DEPARTMENT, THE OKLAHOMA MENTAL HEALTH ASSOCIATION, AND LOCAL NON-PROFIT ORGANIZATIONS SUCH AS THE OKLAHOMA CHAPTERS OF AMERICAN HEART ASSOCIATION, AMERICAN LUNG ASSOCIATION, AMERICAN DIABETES ASSOCIATION, AMERICAN CANCER SOCIETY, AND OTHER LOCAL HEALTH AND WELLNESS ORGANIZATIONS AND AGENCIES TO DETERMINE HEALTH CARE NEEDS IN THE STATE, ISSUES CONCERNING SPECIFIC CITIES, ACCESS TO HEALTH ISSUES, NEIGHBORHOOD AND ENVIRONMENT ISSUES, AND OTHER SOCIAL DETERMINANTS OF HEALTH THAT AFFECT THE LIVES OF OUR RESIDENTS. A VARIETY OF COALITIONS, TASK FORCES, AND COMMITTEES HAVE BEEN STARTED TO ADDRESS SPECIFIC HEALTH AND WELLNESS ISSUES AND TO DETERMINE INTERVENTIONAL STRATEGIES FOR IMPLEMENTATION. THE IMPACT PROGRAMS ARE HAVING ON COMMUNITY HEALTH, ESPECIALLY PREVENTION ACTIVITIES, EFFORTS TO IMPROVE HEALTH AND INCREASE ACCESS TO HEALTH CARE SERVICES, AND REDUCING HEALTH CARE COSTS. INTEGRIS COMMUNITY HEALTH PROGRAMS ACROSS THE STATE ARE IMPLEMENTED TO EDUCATE OUR RESIDENTS ABOUT HEALTH AND WELLNESS ISSUES AFFECTING THEM AND THEIR COMMUNITIES. WORKING WITH PARTNER AGENCIES AND ORGANIZATIONS IN THE COMMUNITIES WE SERVE GIVES US THE OPPORTUNITY TO CREATE PROGRAMS THAT SPECIFICALLY ADDRESS NEGATIVE HEALTH INDICATORS AFFECTING THE COMMUNITY. PREVENTION AND HEALTH EDUCATION HAVE BEEN THE PRIORITY FOR INTEGRIS FOR MANY YEARS IN AN EFFORT TO BETTER EDUCATE THE PUBLIC ON TAKING CARE OF THEIR HEALTH AND CREATING AWARENESS ABOUT HOW THEIR BEHAVIORS MAY NEGATIVELY AFFECT THEIR HEALTH AND THE HEALTH OF THEIR FAMILIES. WORKING WITH PARTNER AGENCIES, ORGANIZATIONS, PHYSICIANS, AND LOCAL CLINICS, INTEGRIS HAS BEEN ABLE TO HELP SLOWLY IMPROVE HEALTH IN SOME INDICATORS, SUCH AS CHILDHOOD IMMUNIZATIONS, ADULT IMMUNIZATIONS, AND SMALL STEP TOWARD IMPROVING CHILDHOOD OBESITY WITH SEVERAL PROGRAMS IMPLEMENTED IN THE METROPOLITAN AREAS, INCREASING ACCESS BY DEVELOPING REFERRAL NETWORKS BETWEEN FREE CLINICS ACROSS OKLAHOMA CITY AND IN SOME RURAL AREAS. ALL OF THESE PROGRAMS AND PARTNERSHIPS, COUPLED WITH EDUCATING THE COMMUNITY ABOUT AVAILABLE SERVICES, CAN HELP US CONTINUE TO REDUCE SOME OF THE HEALTHCARE COSTS WE SEE IN OUR HOSPITALS, CLINICS, AND EMERGENCY DEPARTMENTS. REPORTING GROUP B PART VI, LINE 5: PROMOTION OF COMMUNITY HEALTH OCOM IS A MEMBER OF THE OHA, WHICH ADVOCATES FOR AFFORDABLE, HIGH-QUALITY CARE FOR THE STATE OF OK AND SUPPORTING RURAL HEALTH. WE CONTRACT WITH RESEARCH INTERNATIONAL TO PERFORM IMAGING STUDIES FOR PATIENTS INVOLVED IN RESEARCH. OCOM ALSO PARTICIPATED IN THE HEALTHY OVER HUNGRY CEREAL DRIVE WHICH SUPPORTS THE REGIONAL FOOD BANK OF OKLAHOMA TO HELP SUPPORT OKLAHOMA'S MOST VULNERABLE AND HUNGRY, AS WELL AS PARTICIPATING IN THE OKLAHOMA BLOOD INSTITUTE BLOOD DRIVE TWICE A YEAR.
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SUPPLEMENTAL INFORMATION 12
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REPORTING GROUP A PART VI, LINE 6: AFFILIATED HEALTH CARE SYSTEM ROLES IACC IS A MEMBER OF INTEGRIS HEALTH SYSTEM, OF WHICH INTEGRIS HEALTH, INC. IS THE CONTROLLING MEMBER. INTEGRIS HEALTH SYSTEM IS AN OKLAHOMA HEALTH CARE SYSTEM WHICH SUPPORTS THE COMMUNITY NEEDS ACROSS THE STATE. THE MISSION OF INTEGRIS HEALTH IS TO IMPROVE THE HEALTH OF THE PEOPLE IN THE COMMUNITIES WE SERVE. THE FACILITIES OF OTHER TAXPAYERS ARE LISTED ON THE SCHEDULE H OF THEIR RESPECTIVE FORMS 990. SEE SCHEDULE O, GENERAL STATEMENTS 3 THROUGH 5 FOR ADDITIONAL INFORMATION REGARDING THE INTEGRIS HEALTH SYSTEM. REPORTING GROUP B PART VI, LINE 6: AFFILIATED HEALTH CARE SYSTEM ROLES OKLAHOMA CENTER FOR ORTHOPAEDIC AND MULTI-SPECIALTY SURGERY, LLC (OCOM) WAS RESTRUCTURED EFFECTIVE NOVEMBER 1, 2018 WHEN A NEW JOINT VENTURE WAS FORMED BETWEEN INTEGRIS AMBULATORY CARE CORPORATION (INTEGRIS), AN OKLAHOMA NOT FOR PROFIT CORPORATION THAT IS TAX-EXEMPT UNDER SECTION 501(C)(3), AND USP OKLAHOMA, INC. (USP OK), AN OKLAHOMA FOR PROFIT CORPORATION THAT IS AN AFFILIATE OF UNITED SURGICAL PARTNERS. THIS JOINT VENTURE OPERATED THE OCOM FACILITY DURING THE TAX YEAR. THE JOINT VENTURE IS A PARTNERSHIP FOR WHICH A FORM 1065 IS FILED. HOWEVER, WHEN THE NEW JOINT VENTURE WAS FORMED WITH INTEGRIS, OCOM BECAME SUBJECT TO THE 501(R) PROVISIONS.
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SUPPLEMENTAL INFORMATION 13
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REPORTING GROUP A PART VI, LINE 7: STATE FILING OF COMMUNITY BENEFIT REPORT ALL STATES WITH WHICH THE ORGANIZATION FILES A COMMUNITY BENEFIT REPORT: OK REPORTING GROUP B PART VI, LINE 7: STATE FILING OF COMMUNITY BENEFIT REPORT A COMMUNITY BENEFIT REPORT WAS NOT FILED WITH THE STATE OF OKLAHOMA FOR THE FISCAL YEAR ENDED JUNE 30, 2019. REPORTING GROUP C PART VI, LINE 7: STATE FILING OF COMMUNITY BENEFIT REPORT A COMMUNITY BENEFIT REPORT WAS NOT FILED WITH THE STATE OF OKLAHOMA FOR THE FISCAL YEAR ENDED JUNE 30, 2019.
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SUPPLEMENTAL INFORMATION 14
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REPORTING GROUP B PART VI - REPORTING OF SECTION 501(R)-RELATED ERRORS AND CORRECTIONS: CONTENT OF FINANCIAL ASSISTANCE POLICY (PART V, SECTION B, LINE 15C) PRIOR TO JULY 1, 2019 WHEN 501(R)-COMPLIANT POLICIES WERE ENACTED, OCOM'S CHARITY POLICY DID NOT CONTAIN THE CONTACT INFORMATION OF THE HOSPITAL FACILITY STAFF WHO COULD PROVIDE PATIENTS WITH INFORMATION REGARDING HOW TO APPLY FOR FINANCIAL ASSISTANCE. THROUGH THE COURSE OF IMPLEMENTING POLICIES THAT MET THE 501(R) GUIDELINES, THE BUSINESS OFFICE MANAGER AND CFO DISCOVERED THAT THIS INFORMATION NEEDED TO BE ADDED, MADE THE NECESSARY CHANGES AND ADOPTED IT INTO THE NEW FINANCIAL ASSISTANCE POLICY (FAP). WIDELY PUBLICIZING FINANCIAL ASSISTANCE POLICY (PART V, SECTION B, LINE 16) OKLAHOMA CENTER FOR ORTHOPAEDIC AND MULTI-SPECIALTY SURGERY, LLC (OCOM) WAS RESTRUCTURED EFFECTIVE NOVEMBER 1, 2018 WHEN A NEW JOINT VENTURE WAS FORMED BETWEEN INTEGRIS AMBULATORY CARE CORPORATION (INTEGRIS), AN OKLAHOMA NOT FOR PROFIT CORPORATION THAT IS TAX-EXEMPT UNDER SECTION 501(C)(3), AND USP OKLAHOMA, INC. (USP OK), AN OKLAHOMA FOR PROFIT CORPORATION THAT IS AN AFFILIATE OF UNITED SURGICAL PARTNERS. THIS JOINT VENTURE OPERATED THE OCOM FACILITY DURING THE TAX YEAR. THE JOINT VENTURE IS A PARTNERSHIP FOR WHICH A FORM 1065 IS FILED. HOWEVER, WHEN THE NEW JOINT VENTURE WAS FORMED WITH INTEGRIS, OCOM BECAME SUBJECT TO THE 501(R) PROVISIONS. OCOM UPDATED ITS FAP AND BILLING AND COLLECTION POLICY IN ORDER TO COMPLY WITH 501(R). HOWEVER, THESE AMENDED DOCUMENTS WERE NOT APPROVED OR ADOPTED UNTIL JULY 1, 2019. IT WAS DISCOVERED DURING THE PREPARATION OF THE 2018 SCHEDULE H FOR OCOM THAT THE REQUIREMENT OF MAKING ITS FAP WIDELY PUBLICIZED WITHIN THE COMMUNITY SERVED BY THE HOSPITAL DURING FISCAL YEAR ENDING JUNE 30, 2019 WAS NOT MET. HOWEVER, THIS REQUIREMENT WAS MET PRIOR TO THE FILING OF ITS SCHEDULE H WITH INTEGRIS'S FORM 990 FOR FYE JUNE 30, 2019. THIS INCLUDES HAVING THE FAP DOCUMENTS TRANSLATED INTO THE PRIMARY LANGUAGES SPOKEN BY LIMITED ENGLISH PROFICIENT (LEP) POPULATIONS IN OCOM'S COMMUNITY. IN ORDER TO ENSURE OCOM IS IN COMPLIANCE WITH THESE WIDELY PUBLICIZED REQUIREMENTS OF 501(R) GOING FORWARD, CERTAIN PROCEDURES AND PRACTICES HAVE BEEN PUT IN PLACE BY OCOM, USP OK AND INTEGRIS. THESE INCLUDE MONTHLY TOUCH BASE MEETINGS BETWEEN INTEGRIS AND OCOM, QUARTERLY CHECKS OF OCOM'S WEBSITE FOR PURPOSES OF COMPLIANCE WITH 501(R), AND ADDITIONAL TRAINING AS NEEDED FOR POLICY AND/OR REGULATION CHANGES. AS OF JULY 1, 2019, OCOM HAS MADE ITS FAP, FAP APPLICATION AND FAP PLAIN LANGUAGE SUMMARY AVAILABLE TO PATIENTS UPON REQUEST AND WITHOUT CHARGE IN THE OCOM FACILITY, AND POSTED THOSE DOCUMENTS ON OCOM'S WEBSITE. ALSO, AS OF JULY 1, 2019, OCOM HAS NOTIFIED AND INFORMED INDIVIDUALS WHO RECEIVE CARE FROM THE OCOM FACILITY ABOUT THE FAP AND FINANCIAL ASSISTANCE THROUGH CONSPICUOUS DISPLAYS AT EACH ADMISSION AREA, NOTIFICATIONS INCLUDED ON BILLING STATEMENTS, AND PAPER COPIES OF THE PLAIN LANGUAGE SUMMARY INCLUDED IN THE DISCHARGE SUMMARY. IN ORDER TO STREAMLINE THE PROCESS, PATIENTS ARE NOW GIVEN THE PAPER FAP APPLICATION AND FAP PLAIN LANGUAGE SUMMARY UPON ADMISSION. IN ADDITION, OCOM'S PATIENT FINANCIAL ADVOCATE DISCUSSES THE AVAILABILITY OF FINANCIAL ASSISTANCE ON PRE-PROCEDURE PHONE CALLS WITH PATIENTS. OCOM HAS ALSO EMAILED COMMUNITY GROUPS, INCLUDING THE REGIONAL FOOD BANK OF OKLAHOMA AND THE OKLAHOMA BLOOD INSTITUTE, TO PROVIDE COPIES OF ITS FAP, PROVIDE COPIES OF ITS FAP AND PLAIN LANGUAGE SUMMARY AND A LINK TO OCOM'S WEBSITE, AND ASKED THOSE GROUPS TO PROVIDE THE PLAIN LANGUAGE SUMMARY TO LOW-INCOME PERSONS WHO ARE LIKELY TO QUALIFY FOR FINANCIAL ASSISTANCE FROM OCOM. BILLING AND COLLECTIONS ACTIONS (PART V, SECTION B, LINE 17) NEITHER THE OCOM CHARITY POLICY NOR THE BILLING AND COLLECTION POLICY IN EFFECT FOR THE TAX YEAR EXPLAINED ALL THE COLLECTION ACTIONS THAT OCOM COULD TAKE UPON NONPAYMENT OF PATIENT BILLS. IN THE COURSE OF IMPLEMENTING 501(R) GUIDELINES, THE BUSINESS OFFICE MANAGER AND CFO DISCOVERED THAT THIS INFORMATION NEEDED TO BE ADDED, MADE THE NECESSARY CHANGES AND ADOPTED IT INTO THE NEW POLICIES EFFECTIVE JULY 1, 2019. MAKING REASONABLE EFFORTS TO DETERMINE ELIGIBILITY FOR FINANCIAL ASSISTANCE BEFORE REPORTING PATIENTS TO CREDIT AGENCIES (PART V, SECTION B, LINES 18A AND 19A) PRIOR TO JULY 1, 2019 WHEN 501(R)-COMPLIANT POLICIES WERE ENACTED, OCOM'S CHARITY POLICY AND OCOM'S COLLECTION POLICY DID NOT PROHIBIT OCOM FROM REPORTING A PATIENT TO A CREDIT AGENCY BEFORE MAKING REASONABLE EFFORTS TO DETERMINE THAT PATIENT'S ELIGIBILITY FOR FINANCIAL ASSISTANCE. THROUGH THE COURSE OF IMPLEMENTING POLICIES THAT MET THE 501(R) GUIDELINES, THE BUSINESS OFFICE MANAGER AND CFO DISCOVERED THAT THIS INFORMATION NEEDED TO BE ADDED, MADE THE NECESSARY CHANGES AND ADOPTED IT INTO THE NEW POLICIES. MAKING REASONABLE EFFORTS TO DETERMINE FINANCIAL ASSISTANCE ELIGIBILITY BY PROVIDING A WRITTEN NOTICE REGARDING INTENT TO REPORT TO CREDIT AGENCY AND AVAILABILITY OF FINANCIAL ASSISTANCE, WITH PLAIN LANGUAGE SUMMARY, AT LEAST 30 DAYS BEFORE REPORTING PATIENT (PART V, SECTION B, LINE 20A) OCOM DID NOT PROVIDE WRITTEN NOTICES REGARDING (I) ITS INTENT TO REPORT PATIENTS TO A CREDIT AGENCY FOR FAILURE TO PAY BILLS, AND (II) THE AVAILABILITY OF FINANCIAL ASSISTANCE, AND THAT INCLUDED A COPY OF THE PLAIN LANGUAGE SUMMARY OF OCOM'S FINANCIAL ASSISTANCE POLICY, AT LEAST 30 DAYS BEFORE REPORTING THOSE PATIENTS TO CREDIT AGENCIES, DURING THE TAX YEAR. THROUGH THE COURSE OF IMPLEMENTING POLICIES THAT MET THE 501(R) GUIDELINES, THE BUSINESS OFFICE MANAGER AND CFO DISCOVERED THAT THIS INFORMATION NEEDED TO BE ADDED, MADE THE NECESSARY CHANGES AND ADOPTED IT INTO THE NEW POLICIES. OCOM HAS IDENTIFIED ALL PERSONS FOR WHOM IT REPORTED ADVERSE INFORMATION TO A CREDIT AGENCY BEFORE MAKING REASONABLE EFFORTS TO DETERMINE THAT PERSON'S ELIGIBILITY FOR FINANCIAL ASSISTANCE, AND HAS ASKED THOSE CREDIT AGENCIES TO DELETE THOSE NEGATIVE REPORTS AND ANY RELATED INFORMATION FROM THEIR RECORDS. CHARGES TO FAP-ELIGIBLE INDIVIDUALS GREATER THAN AMOUNTS GENERALLY BILLED (PART V, SECTION B, LINE 23) OKLAHOMA CENTER FOR ORTHOPAEDIC AND MULTI-SPECIALTY SURGERY, LLC (OCOM) WAS RESTRUCTURED EFFECTIVE NOVEMBER 1, 2018 WHEN A NEW JOINT VENTURE WAS FORMED BETWEEN INTEGRIS AMBULATORY CARE CORPORATION (INTEGRIS), AN OKLAHOMA NOT FOR PROFIT CORPORATION THAT IS TAX-EXEMPT UNDER SECTION 501(C)(3), AND USP OKLAHOMA, INC. (USP OK), AN OKLAHOMA FOR PROFIT CORPORATION THAT IS AN AFFILIATE OF UNITED SURGICAL PARTNERS. THIS JOINT VENTURE OPERATED THE OCOM FACILITY DURING THE TAX YEAR. THE JOINT VENTURE IS A PARTNERSHIP FOR WHICH A FORM 1065 IS FILED. HOWEVER, WHEN THE NEW JOINT VENTURE WAS FORMED WITH INTEGRIS, OCOM BECAME SUBJECT TO THE 501(R) PROVISIONS. AMY TAYLOR, THE CFO, INQUIRED TO THE FORMER CEO ABOUT 501(R) POLICIES AND PRACTICES, INCLUDING LIMITATIONS ON CHARGES. SHE THEN DISCUSSED IT WITH TIFFANY THOMPSON, REGIONAL COMPLIANCE OFFICER WHO PUT OCOM IN CONTACT WITH USPI AND INTEGRIS FOR ASSISTANCE. 501(R) WAS FULLY IMPLEMENTED AT OCOM IN JULY 2019. PRIOR TO JULY 2019, BEFORE THE PROVISIONS OF 501(R) WERE IMPLEMENTED, UNINSURED PATIENTS WERE CHARGED A RATE BASED UPON A PERCENTAGE OF MEDICARE, IF THEY QUALIFIED FOR FINANCIAL ASSISTANCE THE SELF-PAY RATE WOULD BE WRITTEN OFF TO CHARITY CARE (OR THE PERCENTAGE THAT THEY QUALIFIED FOR BASED UPON THE FEDERAL POVERTY LEVEL) AND INSURED PATIENTS ACCOUNTS THAT QUALIFIED FOR FINANCIAL ASSISTANCE WOULD BE WRITTEN OFF TO CHARITY CARE (OR THE PERCENTAGE THAT THEY QUALIFIED FOR BASED UPON THE FEDERAL POVERTY LEVEL) ONCE INSURANCE WAS PROCESSED. CURRENTLY, HOWEVER, THE LOOK BACK METHOD, USING PAST PAYMENTS FROM MEDICARE OR FROM A COMBINATION OF MEDICARE AND COMMERCIAL INSURER PAYMENTS, IS THE METHOD THAT INTEGRIS CURRENTLY USES FOR OCOM IN ORDER TO DETERMINE AMOUNTS GENERALLY BILLED (AGB) TO INSURED INDIVIDUALS FOR MEDICALLY NECESSARY SERVICES. THE AMOUNTS CHARGED FOR EMERGENCY AND MEDICALLY NECESSARY MEDICAL SERVICES TO PATIENTS ELIGIBLE FOR FINANCIAL ASSISTANCE WILL NOT BE MORE THAN THE AVERAGE AGB TO INDIVIDUALS WITH INSURANCE COVERAGE FOR SIMILAR SERVICES. INTEGRIS DETERMINES AGB BASED ON ALL CLAIMS PAID IN FULL TO INTEGRIS BY MEDICARE AND PRIVATE HEALTH INSURERS (INCLUDING PAYMENTS FOR MEDICARE BENEFICIARIES OR INSURED INDIVIDUALS THEMSELVES), OVER A 12-MONTH PERIOD, DIVIDED BY THE ASSOCIATED GROSS CHARGES FOR THOSE CLAIMS (LOOK-BACK METHOD). OCOM IS IN THE PROCESS OF IDENTIFYING ALL PERSONS WHOM IT DETERMINED QUALIFIED FOR FINANCIAL ASSISTANCE UNDER ITS FAP, BUT WHOM IT CHARGED MORE THAN AMOUNTS GENERALLY BILLED (AGB) AT MEDICARE RATES FOR EMERGENCY AND OTHER MEDICALLY NECESSARY SERVICES. OCOM PLANS TO ISSUE A REFUND TO ALL OF THOSE PERSONS, TO THE EXTENT REASONABLY FEASIBILE, OF THE AMOUNTS THOSE PERSONS PAID THAT EXCEEDED THE AGB MEDICARE RATES.
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SUPPLEMENTAL INFORMATION 15
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REPORTING GROUP C PART VI - REPORTING OF SECTION 501(R)-RELATED ERRORS AND CORRECTIONS: IN NOVEMBER 2018 THE HPI FACILITIES WERE ACQUIRED BY THE ORGANIZATION. WITH RESPECT TO THE FACILITIES, IT WAS RECENTLY DISCOVERED THAT THEY HAD FAILURES TO MEET THE REQUIREMENTS OF SECTION 501(R) THAT WERE NOT WILLFUL OR EGREGIOUS. AS SOON AS THE DISCOVERY WAS MADE THE FACILITIES INITIATED A PLAN TO CORRECT AND DISCLOSE ANY SUCH FAILURES PURSUANT TO REV. PROC. 2015-21. THE HOSPITAL FACILITIES WILL REPORT THE INFORMATION DESCRIBED IN SECTION 7 OF REV. PROC. 2015-21 ON ITS NEXT FORM 990.
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