Schedule H, Part I, Line 2
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"Part I, Line 2 - The following additional information was provided last year - this issue was cleared during FY 2020, however, keeping this note for one more year as additional information. During April 2017, Lakeview Hospital was transferred to University Healthcare System, L.C.("University"), a joint venture between Tulane University and an affiliate of HCA Healthcare, Inc. Prior to joining University, Lakeview Hospital was wholly-owned and operated by an affiliate of HCA Healthcare, Inc. The patient accounts receivable billing and collection processes are performed by a patient account service center operated by a wholly-owned affiliate of HCA Healthcare, Inc. The same patient accounts service center provides patient accounts receivable billing and collection processes for the hospitals owned and operated by University. With respect to the hospitals operated by University, the billing and collection processes conform to the requirements of IRC Section 501(r). Prior to joining University certain billing and collection processes that were used for Lakeview's patient accounts receivables did not conform to the billing and collection processes required by IRC Section 501(r) as the hospital was not required to meet those requirements. Upon Lakeview Hospital joining University, these certain billing and collection processes were inadvertently not updated to treat Lakeview similarly to hospitals being operated by University. Specifically, certain patient accounts were held by the patient account service center's collections department for approximately 60 days (instead of 120 days from the first billing statement) prior to being sent to primary collection agencies. Once at primary collection agencies, the patient accounts could have been reported to credit bureaus which is an extraordinary collection activity under 501(r) ("ECA"). A subsequent review indicated that approximately 197 patient accounts were reported to a credit bureau agency prior to 120 days from the first billing statement. This credit bureau reporting has been reversed. Additionally, certain accounts were not routed to receive verbal attempts or final notices at least 30 days prior to closing from the patient account service center's collections department. This process has been updated and patient accounts are receiving the verbal attempts before sending final notices of payment due. Additionally, the patient billing statements sent from the patient account service center did not contain language regarding the availability of financial assistance, the phone number for obtaining more information, or the URL for obtaining the Financial Assistance Policy, Financial Assistance Application or Plain Language Summary for Lakeview accounts as required by 501(r). This process issue has been corrected and the required information is being included on patients' billing statements. Any patient accounts that may have been adversely impacted by these issues have been corrected. "
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Schedule H, Part I, Line 7
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Part I, Line 7 a Cost for Charity Care was derived using a cost-to-charge ratio from Schedule H, Worksheet 2 applied in Worksheet 1. Patient revenue is based on GAAP and bad debt is not included in this calculation. No extraordinary items are included in this calculation.
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Schedule H, Part II
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As described in Section H, Part VI, TUHC works in partnership with the Tulane University School of Medicine by staffing and supporting a number of community services. Examples of these are provided in that narrative. The dollar amounts in the table are an approximate representation of the direct costs and offsetting revenues of these activities.
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Schedule H, Part III, Section A, Line 4
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Part III, Section A, Line 4 : Excerpt from audited financial statements related to provision for doubtful accounts - The amount of the provision for doubtful accounts is based upon management's assessment of historical and expected net collections, business and economic condition, trends in federal and state governmental health coverage, and other collection indicators. The provision for doubtful accounts and the allowance for doubtful accounts relate primarily to amounts due directly from patients. Management relies on the results of detailed reviews of historical write-offs and recoveries as a primary source of information to utilize in estimating the collectability of the Company's accounts receivable. The results of the detailed reviews of historical write-offs and recoveries, adjusted for changes in trends and conditions, are used to estimate the allowance for doubtful accounts for the current period. Adverse changes in general economic conditions, business office operations, payer mix, or trends in federal or state governmental health care coverage could affect the Company's collection of accounts receivable, cash flows, and results of operations.
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Schedule H, Part III, Section B, Line 8
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Part III, Section B, Line 8. Even though the amount reported for Medicare activity in Section B reflects a surplus for the year, it should be noted that the amount of patient care costs do not include Medicare non-allowable expenses. The amounts reported on Part III, Lines 5-7, have been determined by aggregating the information from the individual facility cost report.
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Schedule H, Part III, Section C, Line 9b
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Part III, Section, C, Line 9b. Collection of outstanding receivables from third-party payers (Medicare, managed care payers, etc.) is the Hospitals' primary source of cash and is critical to our ability to fund operations. The primary collection risks relate to uninsured patient accounts, including patient accounts for which the primary insurance carrier has paid the amounts covered by the applicable agreement, but patient responsibility amounts (deductibles and copayments) remain outstanding. The provision for doubtful accounts and the allowance for doubtful accounts relate primarily to amounts due directly from patients. An estimated allowance for doubtful accounts is recorded for all uninsured accounts, regardless of the aging of those accounts. Accounts are written off when all reasonable internal and external collections efforts have been performed. Our collection policies include a review of all accounts against certain standard collection criteria, upon completion of our internal collection efforts. Accounts determined to possess positive collectability attributes are forwarded to a secondary external collections agency and the other accounts are written off. The accounts that are not collected by the secondary external collection agency are written off when they are returned to us by the collection agency (usually within 12 months). Write-offs are based upon specific identification and the write-off process requires a write-off adjustment entry to the patient accounting system. We do not pursue collection of amounts related to patients that meet our guidelines to qualify as charity care. The methodology to determine the bad debt expense reported at cost on Part III, Line 2 is to take the ratio of patient care costs to gross patient charges and multiply this resulting ratio by the gross charges for bad debt accounts. See note Part 1, line 2.
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Schedule H, Part VI, Line 2
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A comprehensive Community Health Needs Assessment (CHNA) process was performed for Tulane Medical Center. Tulane Lakeside Hospital, and Lakeview Regional Medical Center and published in October of 2018. It included the collection of primary and secondary data. Community organizations and leaders within the six-parish region were engaged to distinguish the needs of the community. Civic and social organizations, government agencies, educational systems, and health and human services entities were engaged throughout the CHNA. The comprehensive primary data collection phase resulted in the contribution of over 100 community stakeholders/leaders, organizations, and community groups. During the CHNA process, data was collected and analyzed individually for each of the three health facilities due to their distinct geographic regions. The primary data collection consisted of several project component pieces. Community stakeholder interviews were conducted with individuals who represented a) broad interests of the community, b) populations of need or c) person with specialized knowledge in public health. Health provider surveys were collected to capture thoughts and opinions regarding health providers' community regarding the care and services they provide. Community representatives and stakeholders attended a community forum facilitated by Tripp Umbach to prioritize health needs, which will assist in the implementation and planning phase. A resource inventory was generated to highlight available programs and services within the service area. The resource inventory identifies available organizations and agencies that serve the region within each of the priority needs. A robust regional profile (secondary data profile) was analyzed. The regional profile contained local, state and federal data/statistics providing invaluable information on a wide-array of health and social topics. Different socioeconomic characteristics, health outcomes, and health factors that affect residents' behaviors; specifically, the influential factors that impact the health of residents were reviewed and discussed with members of the working group and Tripp Umbach.
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Schedule H, Part VI, Line 3
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In order to ensure that all patients are adequately informed about this policy, Tulane has undertaken the following - "Information about the Financial Assistance Policy, a plain language summary of the policy, and the Financial Assistance Application and instructions for completion are available on the THS website in English, Spanish and Vietnamese at: http://tulanehealthcare.com/patients-and-visitors/pay-your-bill.dot. The financial assistance application is available at the facilities and by mail. Patient brochures are available and distributed explaining the billing process and providing information on the availability of charity discounts and alternatives for uninsured patients. Tulane will provide a descriptive notice of the uncompensated care policy to any individual inquiring about the provision of uncompensated services. Notices highlighting the provision of uncompensated care will be posted prominently in the admission area, business office, outpatient registration sites and the emergency room. Finally, Tulane continues to educate and inform individuals about the uncompensated care policy during the collections process by including a notice of the policy on billing statements.
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Schedule H, Part VI, Line 4
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Tulane services the local and regional community through downtown and suburban clinics located within its geographic area, which includes New Orleans, Metairie, New Orleans East, Northshore, as well as 15 Louisiana parishes and two Mississippi counties. This large geographic area was broken into six regional areas to aid comparison and analysis of primary and secondary data through a regional approach. Tulane Medical Center was included in the New Orleans Regional Profile, Tulane Lakeside Hospital was included in the Jefferson Regional Profile and Lakeview Regional Medical Center was included in the North Shore Regional Profile. Key areas assessed are quality of health care, social and economic determinants, environmental conditions, individual behaviors, heredity, and education. National ratios fo physician/service needs by population volume and age group are used to determine underserved areas.
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Schedule H, Part VI, Line 6
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The 3 hospitals under Tulane Health System work in partnership with the Tulane University School of Medicine under a joint venture with Hospital Corporation of America (HC). The School's faculty staffs and supports the 3 facilities as well as a number of community services. Examples of these ongoing community services include: Fleur de Vie Student Clinic (indigent care); Bridge House Clinic (indigent care for addicts), a Community Health Center servicing indigent clients in a patient focused medical home model; a pediatric/adolescent drop in clinics, and several school based and community based clinics; Ryan White HIV clinics, a training program for community health workers and physician coverage to local, inner city public high schools' sporting events. Over the past few years, Tulane Medical School sponsored a teaching kitchen bringing free classes on health eating to the community. Tulane Health System serves over 280,000 patients per year and has several institutes and centers of excellence that provide advance care to not only Louisianians but also out-of-state residents seeking the latest developments in clinical care.
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