Part I, Line 3c:
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Children's, based on its participation in the state of Massachusetts Health Safety Net, utilizes Federal Poverty Guidelines for determining eligibility for free care and discounted care to low income individuals. For purposes of discounted care, Children's offers discounts to individuals, regardless of income, who are uninsured and are ineligible for free care or other public programs.
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Part I, Line 7:
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Children's used an internal cost accounting system for purposes of reporting certain amounts on Part I, line 7. The system is designed to address all segments of patient care (inpatient, outpatient and emergency) and assigns costs to patients from all payer sources (Medicaid, Medicare, managed care, commercial, uninsured and self-pay). The cost of charity care was determined based on the overall relationship of hospital costs as a percentage of hospital charges, applied to charges that qualified as charity care.Children's provides charity care to all children in need who meet the hospital's charity care standards, which are in alignment with all state mandated regulations. Nearly 30% of children who receive their care at Children's are insured through Medicaid programs in a number of states including Massachusetts. In aggregate, Medicaid programs do not reimburse the hospital for the total costs of providing care to these children. Children's has a strong commitment to improving the health status of the children in our local community. Based on a tri-annual community needs assessment, Children's supports a variety of programs and partners both internal and external that are addressing the needs of Boston children. Children's has also identified four major health focus areas in which it concentrates its efforts. For children in Boston, asthma, mental health, obesity and child development are major concerns. Children's has community based programs in each of these issue areas. The hospital alsohas an Office of Child Advocacy that provides support to these programs.Children's is a leader in education and training for healthcare professionals.Children's subsidizes services that are either limited or unavailable in the broader community. Examples include psychiatry, primary care, and dental care.Recognizing that Children's does not have the capacity to meet all the needs of the children of Boston, it supports through financial contributions and in kind services) a large number of community based organizations who are providing these important services. Beneficiaries range from full service community health centers to Head Start programs for pre-school children.For more information, visit www.childrenshospital.org/community.
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Part I, Line 7g:
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Children's does not subsidize physician services; thus there are none reported in the dollar amount for subsidized health services.
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Part I, Ln 7 Col(f):
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The total bad debt expense of $23,877,752 is included in Form 990, Part IX, line 25 column (A), but subtracted for purposes of calculating the percentage in this column.
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Part I, Line 6a
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Children's files an annual community benefits report with the Attorney General's Office (AG) in Massachusetts. There are significant differences between the AG and IRS requirements for reporting community benefits expenditures. The IRS counts the following as community benefits while the AG does not: Medicaid shortfalls, indirect costs, health professions education, and research funded by tax-exempt and government sources. Children's AG Report is publicly available and can be accessed directly on the AG's web site, www.mass.gov/AG and Children's web site, www.childrenshospital.org.
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Part II, Community Building Activities:
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In FY20, Children's reported two types of community building activities: $1,514,683 for 31 community support programs and $753,517 for community health improvement advocacy. Children's community building activities are designed specifically to address health disparities and improve the health of children, families and communities. According to public health literature (see Ambulatory Pediatrics and Health Affairs), initiatives that address disparities for children across four different levels: the individual, systemic, community and society can lead to meaningful improvements in health.As described in Form 990, Part III Program Service Accomplishments, Children's takes a multi-pronged approach to tackle the most pressing health issues facing Boston children. At the same time, Children's addresses non-health or social determinants of health issues such as violence, workforce development and education, which also impact a child's health. Therefore, Children's directs its community building activities in the following areas:- Children's public policy advocacy efforts help to improve access to health care for all individuals and ensure high-quality pediatric services.- As a major employer in Massachusetts and civic leader in Boston, Children's supports efforts to ensure a diverse and culturally competent health care workforce as well as promotes economic health in thesurrounding communities. - To improve life in local neighborhoods, Children's has targeted support towards community based organizations that do not focus specifically on health, but rather on the vibrancy of the community. Contributions to groups such as the Fenway Community Development Corporation and Sociedad Latina are as important as partnerships with community health centers. For more information, visit http://www.childrenshospital.org/about-us/community-mission.
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Part III, Line 2:
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Bad debt expense reflects patient charges that have been deemed uncollectible, converted to cost based on the ratio of patient care cost to charges from Worksheet 2.
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Part III, Line 3:
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There is not any amount of bad debt reflected as charity care, because it can't be quantified accurately at this time. However, some bad debts would be charity care.
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Part III, Line 4:
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Children's Medical Center and Subsidiaries' Audited Financial Statements does not contain any footnotes describing bad debt.
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Part III, Line 8:
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Medicare allowable costs are obtained directly from the Medicare Cost Report and are determined in accordance with Medicare principles of reimbursement.
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Part III, Line 9b:
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Children's makes reasonable and diligent efforts to collect each patient's insurance and other information and to verify coverage for health care services. Children's applies collection actions to all patients in the same manner, irrespective of their insurance status. Children's does not (and does not permit its agents to) engage in collection action of any kind, including billing, with respect to patients/guarantors that are exempt from collection action under Children's Credit and Collection Policy and under Massachusetts regulations governing the Health Safety Net program. All patients/guarantors who are not exempt from collection action are advised in all billing-related communications of the availability of free care and financial assistance, including assistance in applying for public programs and the availability of charity care. Children's does not (and does not permit its agents to) engage in legal action against patients/guarantors, including liens, wage garnishments, or lawsuits, or report patients/guarantors to credit bureaus or credit agencies without specific, case-by-case authorization by Children's Board of Directors. No legal action occurred during the year. Children's Credit and Collection Policy is filed with the Massachusetts Division of Health Care Finance and Policy. That policy and related policies are also available to patients upon request and on the Hospital's website.
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Part VI, Line 2:
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Boston Children's assesses the community needs on an ongoing basis through continuous dialogue with the community, participation on committees, working groups, and task forces, as well as input from Community Advisory Board and partners.For more information, visit www.childrenshospital.org/community-health/community-health-needs
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Part VI, Line 3:
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Children's provides patients with information about financial assistance programs that are available through the Commonwealth of Massachusetts or through the hospital's own financial assistance program.For those patients that request financial assistance, Children's assists patients by screening them for eligibility in an available public program and assisting them in applying for the program. All patients/guarantors who are not exempt from collection action are advised in all billing-related communications of the availability of free care and financial assistance, including assistance in applying for public programs and the availability of charity care. The screening and application process for a financial assistance programs is done through either the Virtual Gateway (which is an internet portal designed by the Massachusetts Executive Office of Health and Human Services to provide an online application for the programs offered by the state) or through a standard paper application. All Virtual Gateway and paper applications are reviewed and processed by the Massachusetts Office of Medicaid. Hospitals have no role in the determination of program eligibility made by the state, but at the patient's request may take a direct role in appealing or seeking information related to the coverage decisions.
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Part VI, Line 4:
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Boston Children's conducted a community health needs assessment to ensure that it was addressing the most pressing health concerns across Boston and its four priority neighborhoods- Roxbury, Mission Hill, Fenway and Jamaica Plain.FINDINGS:The residents of Boston Children's priority neighborhoods are ethnically and linguistically diverse, with wide variations in socioeconomic levels. Minority and low-income residents are disproportionately affected by the social and economic context in which they live. Demographic Characteristics: Residents and stakeholders commented on the variety of cultures represented in the communities served by Boston Children's. Quantitative data illustrate that racial and ethnic diversity varies across Boston Children's priority neighborhoods and citywide. While the majority of residents in Roxbury/Mission Hill self-identify as Black (60.9%), Fenway and Jamaica Plain have a larger proportion of White residents (70.2% and 62.0%, respectively) compared to the city (53.9%). Poverty, Income, and Employment: Economic data demonstrate that among the priority neighborhoods, a greater proportion of families in Roxbury/Mission Hill (31.0%) were living in poverty compared to families citywide (16.0%). Additionally, nearly half of female headed households with children under five years of age in Boston were living in poverty (46.7%).Education: Quantitative data show that educational attainment across the priority neighborhoods ranges from 71.0% of Fenway residents with abachelor's degree or higher to 25.0% of Roxbury/Mission Hill adults. Additionally, Black and Hispanic students graduate at lower rates than their White and Asian counterparts.Housing: Housing concerns disproportionately affect renters, who represent the majority in Boston; 42.4% of renters in Boston contribute 35% or more of their income to housing costs. Neighborhood Crime and Perceptions of Safety: Quantitative data validate residents' concerns; between January and June 2013, Boston Children's priority neighborhoods collectively accounted for approximately 40% of thetotal crimes reported citywide during this time period, the majority of which were classified as larceny or attempted larceny. Furthermore, over half of all homicides occurred in Roxbury/Mission Hill.There are 4 hospitals and 7 community health centers serving our priority neighborhoods. There are 22 Census Tracks that fall under 2 different MUA/P areas that are within the Boston Children's Hospital priority areas. Massachusetts has a low rate of uninsured children.0-5 years 1.1% uninsured - 35.9% on Medicaid6-18 years 1.5% uninsured - 30.6% on Medicaid19-25 yrs-7% uninsured - 18.9% on Medicaid
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Part VI, Line 5:
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As the only free-standing children's hospital in the state, Children's treats 90% of the sickest kids in Massachusetts and offers a range of services that are unavailable elsewhere in the region, including pediatric transplants, critical care transport services, a level 1 Pediatric Trauma Unit and a level 3 Neonatal Intensive Care Unit. Children's also qualifies for DSH payments as the state's largest provider of pediatric care to low-income families. Approximately 30% of its patients are covered by Medicaid, including patients insured by out-of-state Medicaid programs. In addition, Children's has an open medical staff model.Children's is also a leader in education and training for healthcare professionals. It sponsors 38 Accreditation Council for Graduate Medical Education-accredited training programs, one American Dental Association accredited training program and 15 non-accredited subspecialty fellowships with 512 residents/clinical fellows enrolled in these programs. Children's partners with 27 schools of nursing throughout Massachusetts and New England to provide clinical experiences in pediatrics.Children's offers a variety of continuing education courses designed for health care professionals in pediatric practice. The courses are accredited by the Office of Continuing Education at Harvard Medical School and each hour of instruction is approved for Category 1 credits towards the AMA Physician's Recognition Award. Topics include autism, eating disorders, sports injuries, endometriosis, substance abuse, concussions, strabismus, Type II Diabetes and vascular anomalies. Children's also offers half-day programs titled Pediatric Health Care Summits that are held at local hospitals, such as Beverly Hospital, Lawrence General and South Shore Hospital (Weymouth). Additionally, Children's partners with area community hospitals such as Good Samaritan Medical Center, Holy Family, Lawrence General, South Shore, St. Anne's and St. Joseph's to sponsor Community Hospital Pediatrics Grand Rounds with monthly lectures provided by faculty in medical and surgical sub-specialties.Children's also operates "Career Opportunity Advancement Children's Hospital", a seven-week program for Boston youth to explore health care careers while having a safe and meaningful summer and the program "Student Career Opportunity Outreach Program", designed by Children's nurses to introduce young people to nursing career opportunities.Children's is home to the world's largest and most active research enterprise at a pediatric center. Children's research mission encompasses basic research, clinical research, community service programs and the postdoctoral training of new scientists.Children's has a twenty-one person voluntary Board of Directors. Eighteen of the Board members are not direct employees of the hospital and all of them live in the hospital's service area. The Board oversees the Hospital's endowment and follows a 4% spending rule in keeping with the industry standard of the responsible management of assets. Reserves are invested back into patient care, teaching, research, patient safety andquality initiatives, equipment, facilities, community benefits and to subsidize vital services that run a deficit.
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Part VI, Line 6:
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Although Children's does not have true affiliates as defined by the IRS, it does have other affiliations.As the largest pediatric referral center in the region, Children's maintains a variety of relationships with community hospitals and other smaller pediatric programs throughout New England. These relationships include seven community hospitals in eastern Massachusetts where Children's physicians have formal arrangements to provide on-site emergency medicine, inpatient, neonatal and/or outpatient pediatric specialty services. Children's also owns and operates five outpatient facilities in Waltham, Lexington, Peabody, North Dartmouth and Jamaica Plain that offer access to pediatric specialty care in a wide array of subspecialties. Children's provides assistance to other pediatric facilities (Hasbro, RI, Dartmouth Hitchcock, NH, and Boston Medical Center) in the region through training, recruitment, consultations, on-site care and referrals for care that is not otherwise available.In addition, the Pediatric Physicians Organization at Children's brings together pediatricians, pediatric medical groups and pediatric specialists at Children's.
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Part VI, Line 7, Reports Filed With States
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MA
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501(r) Reporting under IRS Revenue Procedure 2015-21
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In June 2020, outside counsel reviewed the processes and procedures implemented by Boston Children's Hospital (BCH) in connection with its Financial Assistance Policy, Credit & Collection Policy, Plain Language Summary and Community Health Needs Assessment, to determine compliance with 501(r) requirements. As a result of these reviews, a number of apparent omissions, errors and other failures to meet requirements, as described below, were discovered. BCH promptly took steps to correct these omissions, errors and failures, as described below. Processes and procedures were also put in place to ensure that these omissions, errors and failures do not recur. Financial Assistance Policy ("FAP"): Publicizing FAP and Related Documents:Plain Language Summary While BCH has historically posted the plain language summary of its FAP on its public website, it has not consistently offered to patients a copy of the plain language summary as part of the intake or discharge process. As of July 18, 2020, the plain language summary has been offered during the discharge process for patients treated in the Emergency Department. As of October 1, 2020, the plain language summary has also been offered as part of the intake process by hospital based clinics, and offering of the plain language summary has been incorporated into the pre-admissions and admissions intake processes. A prompt in Epic to offer the plain language summary appears in Epic during the intake process for outpatient visits, inpatient admissions, and day surgery and during the discharge process for patients who presented in the ED and for inpatients who were not offered the plain language summary during the intake process.BCH is not aware of any individuals affected by this error and believes there were no individuals adversely affected because any individual applying for financial assistance or expressing concern regarding ability to pay for care was provided with financial counseling and made aware of the availability of financial assistance and the process for applying for financial assistance. In addition, the plain language summary is and has been available on BCH's public website. Website Address on Billing StatementWhile BCH has historically included a conspicuous written notice on its billing statements of the telephone number for its financial counseling office, which includes staff who are available to help identify financial assistance available, BCH had not included on its billing statements the direct website address where copies of the Financial Assistance Policy (FAP), FAP Application form and plain language summary could be accessed. BCH added the direct website address to billing statements as of July 20, 2020. BCH does not believe that any individuals have been adversely affected as result of this oversight, since the contact information of the department able to provide information about the FAP and able to assist with the FAP application process was provided on the billing statements. Updating the billing statement addressed the failure to comply with these requirements, so no additional practices or procedures were necessary to minimize the likelihood of such failures recurring. This omission would have impacted all patients who received billing statements prior to July 20, 2020, when the error was corrected. It is not reasonably feasible for BCH to restore individuals to the position they would have been in had this information not been omitted, as this would require sending billing statements to all individuals who received them prior to correction of the error, which would likely cause confusion for individuals who have settled their bills with BCH. Translations of FAP and Related Documents While BCH had provided translations of its FAP, FAP application form and plain language summary for ten (10) limited English proficiency groups, based on an update of its analysis of the limited English proficiency groups in the community served by BCH and the population likely to be affected or encountered by BCH, BCH needed to make available translations of these documents in three additional languages: Russian, Italian and Somali. BCH made available translations of these documents in Somali as of June 20, 2020, and in Russian and Italian as of August 4, 2020. BCH is unaware of any individuals being adversely affected as a result of this omission and believes there were no individuals adversely affected because BCH provides any individual with limited English proficiency access to an interpreter to assist in any financial assistance matters. In addition, BCH has implemented a process to (a) review data related to limited English proficiency groups annually; (b) update the list of languages into which the FAP, FAP Application form and plain language summary need to be translated; (c) obtain translations needed in any additional languages; and (d) make those translations available to our patients and their families. It is not reasonably feasible for BCH to restore individuals to the position they would have been in had the failure not occurred. This would require identifying all patients who accessed these documents and who might have needed translations of these documents in one of these three additional languages, which is likely not possible. Provider ListBCH discovered in May, 2020 that, while BCH has historically posted its FAP provider list, the provider list had not been updated at least every 90 days. BCH updated its provider list on May 20, 2020, and has implemented a process to ensure that it is updated at least quarterly thereafter. BCH is not aware of any individuals being adversely affected as a result of this error.BCH has assigned to a supervisor and a manager the responsibility to update the provider list on a quarterly basis. These staff members will review a report generated by BCH's Credentialing and Enrollment department, which includes all providers who have been granted medical staff privileges by BCH. If BCH has added any new practices or providers that/who were not on the provider list posted, the revised provider list will be sent for translation and the revised provider list, along with all required translations will be posted on BCH's external website. It is not reasonably feasible for BCH to restore individuals to the position they would have been in had the failure not occurred. This would require identifying all patients who accessed the provider list, and providing the updated list to those patients, which would include many who are not in active treatment and may cause confusion. Methodology for Calculating AGB:While BCH had posted and otherwise made available a methodology for calculating amounts generally billed ("AGB"), BCH had in practice used a different methodology to calculate the AGB applied to bills of individuals eligible for financial assistance. The methodology used was more favorable (i.e., the discount applied was greater than the discount that would have been applied using the posted AGB methodology). BCH updated the AGB methodology to reflect the methodology it uses to calculate AGB, and posted and otherwise made available the updated methodology on May 20, 2020. Following the close of each fiscal year (which usually occurs by the end of each calendar year), BCH's Finance and Reimbursement department will gather the information necessary to calculate the AGB, and calculate AGB. Patient Financial Services will make any changes to the AGB document required, based on such annual calculation. The updated AGB will then be posted on BCH's external website. BCH does not believe any individual was adversely affected by this error, as the methodology used was favorable to patients. Therefore, BCH has not attempted to restore individuals to the position they would have been in had the failure not occurred.
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