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What to Know About Medical Debt

March 19, 2024

Presentation for BAILA

Shelly Tsai, Staff Attorney

Health Consumer Center

www.nlsla.org

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Presentation Overview

Introduction

Medi-Cal Updates

Medical Debt

Definition

Advocacy Tips

Billing Protections

Debt Collection

Litigation

Referral

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        • Nonprofit legal services organization (1965)
        • Offices throughout LA Count
        • Free legal assistance to eligible residents of LA County
        • General legal assistance (800) 433-6251
        • Apply for services online: http://www.nlsla.org

Neighborhood Legal Services

www.nlsla.org

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Health Consumer Center

        • HelpLine for health access advocacy.
        • Free info, legal advice, and direct representation in administrative proceedings, state or federal courts.
        • Cases we do not accept: medical malpractice, Social Security disability appeals, and Employee Retirement Income Security Act (ERISA) lawsuits

www.nlsla.org

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Medical Debt Project

WE DON’T:

        • Pay off your debt.
        • Repair your credit.
        • Handle veterinary bills.

WE CAN:

        • Help with these types of debts:
          • Hospitals, nursing homes, ambulance, doctors, labs
          • Medical financing products (credit cards, loans)
        • Provide legal assistance no matter where you are in the process.

WE PRIORITIZE:

        • Legal representation for debtors at risk of homelessness due to medical debt who are:
      • Seniors 60+, or
      • Regional center clients, or
      • Low-income (≤ 200% FPL)

www.nlsla.org

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Eligibility for fullscope Medi-Cal regardless of immigration status

1

Asset test for Medi-Cal program eliminated

2

Medi-Cal enhanced care management & community supports

3

Medi-Cal

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What is Medical Debt?

        • No insurance
        • Billed at full price
        • Low premiums
        • High cost-sharing
        • Coding disputes
        • Plan denials
        • Out-of-network
        • Excluded services

Uninsured

Underinsured

Fully Insured

Amount owed after receiving medical services or goods

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Avoiding Medical Debt

Use network providers or obtain permission to go outside the network

As your plan’s Member Services or care coordinator for help.

Use county medical facilities

When in doubt, go to county facilities for lower rates.

Purchase travel insurance if you are going out-of-state or going abroad.

Pay no more than in-network cost-sharing for emergency medical services received within the U.S.A.

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Avoiding Medical Debt

Avoid using ambulance if possible

Have family member or friend drive to the hospital.

Timely file an appeal

File an appeal if the plan denied the request to go out-of-network or refuses to cover for services.

Do not sign paperwork you do not understand

If possible, ask for time to review the document. Request translated copy in your primary language.

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Advocacy Tips for Medical Bills

01

Know your rights (leverage).

02

Document all disputes in writing.

03

Don’t rush to pay a bill if you just received the services.

04

Don’t pay a bill for medical services from more than 4 years ago without first seeking legal advice.

05

It’s never too late to negotiate, but the longer you wait, the more limited your options.

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Advocacy Tips for Medical Bills

Check

Check the bills for mistakes.

          • Are you legally responsible for the debt?
          • Did you receive billed services?
          • Look for duplicate charges.

Compare

Compare your bill with the insurer’s explanation of benefits.

          • Billing codes and descriptions match?
          • Patient responsibility amounts match?

Appeal

Appeal your insurer’s decisions if you think they should be paying more.

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State law requires California hospitals to send a notice with an application for the hospital financial assistance program before sending the account to collections.

Hospital Billing Protections

State law prohibits credit reporting or bringing a nonpayment lawsuit for 180 days from initial billing for a hospital stay.

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Hospital Billing Protections (cont’d)

State law limits expected payment for services (income at or below 400% FPL) at Medicare or Medi-Cal rate, whichever is greater.

Federal law prohibits hospitals and emergency physicians from billing insured patients beyond their in-network cost-sharing amount even if they do not contract with the insurer.

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Hospital Financial Assistance

Apply for hospital financial assistance program if you cannot pay the bill.

California hospitals must offer financial assistance (for free or discounted care) to patients with limited means to pay.

          • Download the policy and application from hospital website.

          • Call the hospital to request a copy of the policy and paper application.

          • Even if you do not qualify for financial assistance, you can still negotiate.

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Ambulance Bills

Effective 1/1/2024:

    • Commercially insured patients cannot be billed more than in-network cost-sharing.

    • Uninsured patient’s liability is limited to Medi-Cal or Medicare rate, whichever is greater.

Some ambulance companies may offer their version of financial assistance.

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Balance Billing

Balance billing is when a healthcare provider bills a patient for the difference between the amount they charge and the amount that the patient's insurance approves.

    • A provider cannot balance bill a Medi-Cal patient for covered services.
    • A contracted (in-network) provider cannot balance bill a managed care subscriber.
    • Balance billing is allowed if a PPO subscriber went to a non-contracted provider.

Provider’s OON:

Balance Bill: $4,500 ($7,000 - $2,500)

Patient Billed: Balance Bill + OON Coinsurance

Example:

PPO Plan

Anesthesiologist Charged: $7,000

Insurance Allowed: $2,500

Co-Insurance (out-of-network): 40%

Co-Insurance (network): 20%

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California No Surprise Bill Protections

A surprise medical bill is an unexpected bill from an out-of-network provider or at an out-of-network facility.

Patients are only billed for their in-network cost-sharing, and no more than that, when they select an in-network facility for non-emergency medical care. This applies even if a provider is out-of-network (e.g., anesthesiologist, radiologist, surgeon, etc.)

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Medical Financing Protections

Credit Card Arranged / Established by the Medical Provider

Must give a written translation of the proposed contract in the language (Spanish, Chinese, Tagalog, Vietnamese, Korean) used in negotiations. Otherwise, the contract is not enforceable under California law.

Must provide a copy of the treatment plan and a list of services that are being charged in advance.

Must tell the patient how much the insurance plan will cover for each service or that a particular service is not covered by insurance.

At patient’s request, must refund to the lender (i.e., credit card) within 15 business days for costs that has not been incurred.

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    • Debt collection practices must comply with state and federal laws.
    • Request debt validation.
    • Dispute debt in writing.
    • Debtors may limit communications.
    • Debt collectors and debt buyers must notify California debtors if they are attempting to collect a debt that is past the statute of limitations.
    • File complaint with Department of Financial Protection and Innovation.

Debt Collections

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Lawsuit

Consult with a lawyer as soon as possible.

Timely respond to the lawsuit if appropriate. Generally, 30 days to respond.

If hospital debt, can still submit the financial assistance application.

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Judgment enforced by garnishment of wages or levying assets.

Judgment debtor may request the court exempt some or all property from collection of a judgment.

Judgment

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Enforcement of Judgment

Starting 1/1/2023: a judgment can only be renewed once for 5 years and capped and capped at 5% if:

    • Judgement debtor is a person, not a business or government agency; and
    • Principal balance owed is less than $200,000 for medical expense, or less than $50,000 for personal debt; and
    • The money owed is not due to a tort, fraud, unpaid wages, or other money owed to an employee.

Starting 9/1/2023: maximum amount to withhold (if any) for wage garnishment is the lesser of two amounts:

20% of the employee’s disposable earnings for the week; or

40% of the difference between the employee’s disposable earnings for that week, and the applicable minimum wage for that week.

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How to Refer to HCC

(1) Phone:1-800-896-3202, Mondays through Fridays 9 AM-5 PM

(2) Email: hccreferral@nlsla.org Provide: name of consumer (or contact person), phone number, short description of the problem, and any language support or accommodation needed.

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Questions

        • Contact Information
        • ShellyTsai@nlsla.org

www.nlsla.org