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Policy #: 8.23
Issued: November 2016, March 2019, November 2019, March 2023
Reviewed/Revised:
Section: Finance____________________________________FINANCIAL ASSISTANCE
Purpose:To provide financial assistance counseling to DotHouse Health patients
Policy Statement:
The purpose of this policy is to provide DotHouse Health patients with financial
counseling and assistance with applying for health insurance.
Application:
None
Exceptions:
None
Procedure:
DotHouse Health Inc. (“DHH“) in partnership with Boston Medical Center and its licensed
community health centers, is to provide consistently excellent and accessible services to all in
need of care, regardless of status or ability to pay. Its vision is to meet the health needs of thepeople of Boston and its surrounding communities by providing high quality, comprehensive
care to all, particularly mindful of the needs of vulnerable populations, through its integrated
delivery system, in an ethically and financially responsible manner.
This policy applies to DHH and its providers, as identified in this policy.
DHH is the frontline caregiver in providing medically necessary care for all people who
present to its facility, regardless of ability to pay. DHH offers this care for all patients thatcome to our facility during our business hours. As a result, DHH is committed to provide
all of our patients with high-quality care and services. As part of this commitment, DHH
works with individuals with limited incomes and resources to find available options tocover the cost of their care.
DHH will help uninsured and underinsured individuals apply for health coverage througha public assistance program or DHH’s financial assistance program (including but notPage: 2

limited to Mass Health, the premium assistance payment program operated by the HealthConnector, the Children’s Medical Security Program, the Health Safety Net, and Medical
Hardship), and will work with individuals to enroll as appropriate. Assistance for these
programs is determined by reviewing, among other items, an individual’s householdincome, assets, family size, expenses, and medical needs. In addition, DHH will also assist
patients in determining the HRSA sliding fee discount program.
While DHH assists patients in obtaining health coverage through public programs andfinancial assistance through other sources whenever appropriate, DHH may also be
required to appropriately bill for and collect specific payments, which may include but not
be limited to, applicable co-payments, deductibles, deposits, and other amounts for which
the patient agrees to be responsible. When registering for services or if receiving a bill,
DHH encourages patients to contact our staff to determine if they and/or a family member
are in need of and eligible for financial assistance.
In working with patients to find available public assistance or coverage through DHH’s
financial assistance, DHH does not discriminate on the basis of race, color, national origin,citizenship, alienage, religion, creed, sex, sexual orientation, gender identity, age, or disability
in its policies or in its application of policies, concerning the acquisition and verification offinancial information, preadmission or pretreatment deposits, payment plans, deferred or
rejected admissions, determination that an individual qualifies for Low Income Patient status
as determined by the Massachusetts Mass Health/Connector eligibility system, or attestationof information to determine Low Income patient status. As such, this policy was reviewed andapproved by the Board of Directors of DHH.
While we understand that each individual has a unique financial situation, information andassistance regarding eligibility for public assistance programs and/or coverage through
DHH’s financial assistance program may be obtained by contacting the Financial
Counseling Department located at 1353 Dorchester Ave., Dorchester, MA 02122, Monday
through Friday, 8AM to 8PM, and Saturday 9 AM to 1 PM to speak with one of
DotHouse Heath’s Financial Counselors.
More information about this policy and DHH’s financial assistance program, including theapplication form and a plain language summary of the financial assistance policy, isavailable on DHH’s website: www.Dothousehealth..org.

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A copy of the financial assistance policy is also available:(1) In any patient registration area within DHH;
(2) By requesting that a copy be mailed to the individual. This request may be madeby calling the Financial Counseling Department at 617-288-3230 or by making
a written request to the address below:
DotHouse HealthAttention: Financial Counseling Office1353 Dorchester Avenue
Dorchester, MA 02122
The actions that DHH may take in the event of nonpayment are described in DHH’s
separate billing and collections policy. Members of the public may obtain a free copy ofthe billings and collections policy:(1) In any patient registration area within DHH(2) By downloading the policy from DHH website, www.dothousehealth.org(3) By requesting that a copy be mailed to the individual. This request may be madeby calling the Financial Counseling Department at 617-288-3230 or by making
a written request to the address below:
DotHouse HealthAttention: Financial Counseling Office1353 Dorchester Avenue
Dorchester, MA 02122
I.

Coverage for Medically Necessary Health Care Services

DHH provides medically necessary medical and behavioral health care services for all
patients who present at DHH regardless of their ability to pay. Medically necessary
services includes those that are reasonably expected to prevent, diagnose, prevent theworsening of, alleviate, correct, or cure conditions that endanger life, cause suffering or
pain, cause physical deformity or malfunction, threaten to cause or aggravate a disability,
or result in illness or infirmity. Medically necessary services at DHH include outpatient
services as authorized under Title XIX of the Social Security Act.
The treating medical professional will determine the type and level of care and treatmentthat is necessary for each patient based on the patient’s presenting clinical symptoms andthe applicable standards of practice.

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Classification of emergency and nonemergency services is based on the following generaldefinitions, as well as the treating clinician’s medical determination. The definitions ofurgent care services provided below are further used by DHH for the purposes ofdetermining allowable urgent bad debt coverage under DHH’s financial assistanceprogram, including the Health Safety Net.
A. Emergency and Urgent Care Services
Any patient who presents at DHH requesting emergency level or urgent care services will
be evaluated based on the presenting clinical symptoms without regard to the patient’s
identification, insurance coverage, or ability to pay. DHH will not engage in actions that
discourage individuals from seeking emergency or urgent medical care, such as demandingthat patients pay before receiving treatment for emergency medical conditions, orinterfering with the screening for and providing of emergency medical care by first
discussing DHH’s financial assistance program or eligibility for public assistanceprograms.
a. Emergency Level Services include treatment for:i.

A medical condition, whether physical or mental, manifesting itself bysymptoms of sufficient severity, including severe pain, such that the absenceof prompt medical attention could reasonably be expected by a prudent
layperson who possesses an average knowledge of health and medicine toresult in placing the health of the person or another person in serious
jeopardy, serious impairment to bodily functions, or serious dysfunction of
any bodily organ or part, or, with respect to a pregnant woman, as further
defined in 42 U.S.C. § 1395dd(e)(1)(B).

b. Urgent Care Services include treatment for:i.

Medically Necessary Services provided in DHH after the sudden onset of a
medical condition, whether physical or mental, manifesting itself by acute
symptoms of sufficient severity (including severe pain) such that a prudent
layperson would believe that the absence of medical attention within 24 hours
could reasonably expect to result in placing a patient’s health in jeopardy,
impairment to bodily function, or dysfunction of any bodily organ or part.
Urgent Care Services are provided for conditions that are not life threatening
and do not pose a high risk of serious damage to an individual’s health. Urgent
Care Services do not include Primary or Elective Care.

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B. Non-Emergent, Non-Urgent Services:
For patients who (1) the treating clinician determines require non-emergent or non-urgent
level care or (2) seek care and treatment following stabilization of an emergency medical
condition, DHH may deem that such care constitutes primary or elective services.
a. Primary or Elective Services include medical care that is not an Urgent or Emergency
level of care and is required by individuals or families for the maintenance of health andthe prevention of illness. Typically, these services are medical or behavioral healthprocedures and visits scheduled in advance or on the same day by the patient or by thehealth care provider at DHH. Primary Care consists of health care services customarily
provided by general practitioners, family practitioners, general internists, general
pediatricians, and primary care nurse practitioners or physician assistants in a primary careservice. Primary Care does not require the specialized resources of an Acute Hospitalemergency department and excludes Ancillary Services and maternity care services.
b. Non-emergent or non-urgent health care services (i.e., primary or elective care) may bedelayed or deferred based on the consultation with DHH’s clinical staff, as well as thepatient’s primary care or treating provider, if available and as appropriate. Coveragefor healthcare services, including medical and behavioral health, is determined andoutlined in a public and private health insurer’s medical necessity and coverage
manuals. While DHH will attempt to determine coverage based on the patient’s known
and available insurance coverage, it may bill the patient if the services are not areimbursable service and the patient has agreed to be billed.
c. Coverage from a public, private, or DHH based financial assistance program may not
apply to certain primary or elective procedures that are not reimbursable by suchcoverage options. If the patient is unsure whether a service is covered, the patient
should contact DHH’s staff in the Financial Counseling Department, located at 1353
Dorchester Avenue, Dorchester, MA 02122, to determine what coverage options areavailable.
II.

Public Assistance Programs and Center Financial AssistanceA. General Overview of Health Coverage and Financial Assistance Programs
DHH’s patients may be eligible for free or reduced cost of health care services
through various state public assistance programs as well as DHH’s financial
assistance programs (including but not limited to Mass Health, the premium
assistance payment program operated by the Health Connector, the Children’s
Medical Security Program, the Health Safety Net Medical Hardship and sliding fee
discount program). Such programs are intended to assist low-income patients by
taking into account each patient’s ability to contribute to the cost of the patient’scare. For those individuals that are uninsured or underinsured, DHH will, whenrequested, help them with applying for either coverage through public assistanceprograms or DHH’s financial assistance programs that may cover all or some of
their unpaid DHH bills.

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B. State Public Assistance Programs
DHH is available to assist patients in enrolling in state health coverage programs. These
include Mass Health, the premium assistance payment program operated by the state’sHealth Connector, and the Children’s Medical Security Plan. For these programs,
applicants can submit an online application (located on the state’s Health Connector
Website), a paper application, or over the phone with a customer service representativefrom either Mass Health or the Connector. Individuals may also ask for assistance from
DHH’s financial counselors by submitting online and paper applications.
C. DotHouse Health Financial Assistance
DHH also provides financial assistance to patients whose income demonstrates an inability
to pay for all or a portion of services provided. Patients who are Massachusetts residents
and/or in DHH’s service area may be required to complete their state’s application for
Medicaid coverage or subsidized health insurance prior to seeking coverage through
DHH’s own financial assistance options. Qualifying patients are eligible for DHH’s
Financial Assistance Policy based on the below criteria:
C.1 Center Financial Assistance through the Health Safety Net:
Through its participation in the Massachusetts Health Safety Net, DHH provides financial
assistance to low-income uninsured and underinsured patients who are Massachusetts
residents and who meet income qualifications. The Health Safety Net was created to more
equitably distribute the cost of providing uncompensated care to low income uninsured andunderinsured patients through free or discounted care across acute hospital and community
health centers in Massachusetts. The Health Safety Net pooling of uncompensated care isaccomplished through an assessment of each hospital to cover the cost of care for uninsured
and underinsured patients with incomes under 300% of the federal poverty level. DHH’s
financial assistance policy includes the health safety net services as part of theuncompensated care provided to low income patients.
Through its participation in the Health Safety Net, low-income patients receiving services
at DHH may be eligible for financial assistance, including free or partially free care for
Health Safety Net eligible services defined in 101 CMR 613:00.

(a) Health Safety Net – Primary

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Uninsured patients who are Massachusetts residents with verified Mass Health MAGI
household Income o of the Federal Poverty Level (FPL) may be determined eligiblefor Health Safety Net Eligible Services.
The eligibility period and type of services for Health Safety Net - Primary are limited
for patients eligible for enrollment in the Premium Assistance Payment Program
operated by the Health Connector as described in 101 CMR 613.04(5)(a) and(b).Patients subject to the Student Health Program requirements of M.G.L. c. 15A, §18 are not eligible for Health Safety Net – Primary.
(b) Health Safety Net – Secondary
Patients that are Massachusetts residents with primary health insurance and Mass
Health MAGI Household income or Medical Hardship Family Countable Income, as
described in 101 CMR 613.04(1), between 0 and 300% of the FPL may be determined
eligible for Health Safety Net Eligible Services. The eligibility period and type ofservices for Health Safety Net - Secondary is limited for patients eligible for enrollment
in the Premium Assistance Payment Program operated by the Health Connector as
described in 101 CMR 613.04(5)(a) and (b). Patients subject to the Student Health
Program requirements of M.G.L. c. 15A, § 18 are not eligible for Health Safety Net –Primary.
(c) Health Safety Net - Partial Deductibles
Patients that qualify for Health Safety Net Primary or Health Safety Net - Secondarywith Mass Health MAGI Household income or Medical Hardship Family Countable
Income between 150.1% and 300% of the FPL may be subject to an annual deductible
if all members of the Premium Billing Family Group (PBFG) have an income that is
above 150.1% of the FPL. This group is defined in 130 CMR 501.0001.
If any member of the PBFG has an FPL below 150.1%, there is no deductible for any
member of the PBFG. The annual deductible is equal to the greater of:
1. The lowest cost Premium Assistance Payment Program Operated by the HealthConnector premium, adjusted for the size of the PBFG proportionally to the Mass
Health FPL income standards, as of the beginning of the calendar year; or
2. 40% of the difference between the lowest Mass Health MAGI Householdincome or Medical Hardship Family Countable Income, as described in 101 CMR
613.04(1), in the applicant's Premium Billing Family Group (PBFG) and 200% of
the FPL.
(d) Health Safety Net - Medical HardshipPage: 8

A Massachusetts resident of any income may qualify for Medical Hardship through the
Health Safety Net if allowable medical expenses have so depleted his or her countable
income that he or she is unable to pay for health services. To qualify for Medical
Hardship, the applicant’s allowable medical expenses must exceed a specified
percentage of the applicant’s Countable Income defined in 101 CMR 613 as follows:
Income Level
0 - 205% FPL
205.1 - 305% FPL
305.1 - 405%
405.1 - 605% FPL>605.1% FPL

Percentage of Countable Income
10%
15%
20%
30%
40%

The applicant’s required contribution is calculated as the specified percentage of Countable
Income in 101 CMR 613.05(1)(b) based on the Medical Hardship Family’s FPL multipliedby the actual Countable Income less bills not eligible for Health Safety Net payment, forwhich the r Medical Hardship Family income, as described in 101 CMR 613.04(1),between 0-300%
Applicant will remain responsible. Further requirements for Medical Hardship are
specified 101 CMR 613.05.
C.2. Charitable Care provided for HSN Eligible Individuals:
Individuals that meet the eligibility requirements to qualify for financial assistanceunder an HSN program outlined in I.C1 of the policy may have existing billing forservices rendered prior to the 10 days that precede the application for HSN coverage.
Under HSN regulations, certain primary and elective services will not be eligible forcoverage under HSN prior to the 10 day period, and the individual remains liable forsuch invoice amounts. At the time HSN eligibility is determined, DHH will provide
for 100% charitable care coverage of these invoices for services rendered prior to the
10 day period and will not engage in further collection on these invoices.

C.3. Center Financial Assistance Sliding Fee Discount Program:
Individuals that met the eligibility requirements to qualify for DHH’s Sliding Fee
Discount Program may be eligible for additional discounts, based upon income andfamily size. Individuals with income levels at or below 200% FPL may qualify.

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D. Limitations on Charges
DHH will not charge any individual who is eligible for assistance under its financial
assistance policy for emergency, urgent, and medically necessary care more than the“amount generally billed” to individuals who have insurance for such care. For thispurpose, the “amount generally billed” is determined using the Medicare reimbursement
rate.
DHH will charge any individual who is eligible for assistance under its financial assistancepolicy for all other care an amount that is less than gross charges for such care.
E. Notices & Application for Center Financial Assistance and Public
Assistance
Programs
E.1 Notices of Available DHH’s Financial Assistance & Public Assistance Options:
For those individuals who are uninsured or underinsured, DHH will work with patients toassist them in applying for public assistance and/or DHH’s financial assistance programs
that may cover some or all of their unpaid DHH bills. In order to help uninsured andunderinsured individuals find available and appropriate options, DHH will provide allindividuals with a general notice of the availability of public assistance and financial
assistance programs during the patient’s initial in-person registration at DHH, in all billinginvoices that are sent to a patient or guarantor, and when the provider is notified or throughits own due diligence becomes aware of a change in the patient’s eligibility status for public
or private insurance coverage.
In addition, DHH also posts general notices at service delivery areas where there is a
registration or check-in area and in general business office areas that are customarily used by
Patients (e.g., registration areas or patient financial services offices that are actively open to
the public). The general notice will inform the patient about the availability of public
assistance and DHH’s financial assistance (including Mass Health, the premium assistancepayment program operated by the Health Connector, the Children’s Medical Security
Program, the Health Safety Net, Medical Hardship and Sliding Fee Discount program) as
well as the location(s) within DHH and/or the phone numbers to schedule an appointment
with a financial counselor. The goal of these notices is to assist individuals in applying forcoverage within one or more of these programs.
E.2. Application for DHH Financial Assistance and Public Assistance Programs:
DHH is able to assist patients in enrolling in a state public assistance program. These
include Mass Health, the premium assistance payment program operated by the state’sHealth Connector, and the Children’s Medical Security Plan. Based on information
provided by the patient, DHH will also identify available coverage options though its

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financial assistance program, including the Health Safety Net, Medical Hardship programs
and Sliding Fee discount program.

For programs other than Medical Hardship, applicants can submit an online application(located on the state’s Health Connector Website), a paper application, or over the phonewith a customer service representative from either Mass Health or the Connector.
Individuals may also ask for assistance from DHH’s financial counselor with submitting
online or paper applications.
For Medical Hardship, DHH will work with the patient to determine if a program such as
Medical Hardship would be appropriate and submit a Medical Hardship application to the
Health Safety Net. It is the patient’s obligation to timely provide all necessary information
as requested by DHH to ensure that DHH can submit a completed application. If the patientis able to provide all information in a timely manner, DHH will endeavor to submit the
total and completed application within five (5) business days of receiving all necessary andrequested information. If the total and completed application is not submitted within fivebusiness days of receiving all necessary information, collection actions may not be taken
against the patient with respect to bills eligible for Medical Hardship.
DHH may also assist patients with enrolling in the Health Safety Net using a presumptive
determination process, which provides a limited period of eligibility. This process isconducted by DHH staff, who, on the basis of self-attestation of financial information fromthe patient, will deem a patient as meeting the low income patient definition and will becovered for Health Safety Net services only. Coverage will begin on the date that theprovider makes the determination through the end of the following month in which thepresumptive determination is made. However, coverage may be terminated sooner if thepatient submits a full application as described above.
E.3 Role of DHH Financial Counselor:
DHH will help uninsured and underinsured individuals apply for health coverage througha public assistance program (including but not limited to Mass Health, the premium
assistance payment program operated by the Health Connector, and the Children’s Medical
Security Program), and work with individuals to enroll them as appropriate. DHH will
also help patients that wish to apply for financial assistance from DHH, which includes
coverage through the Health Safety Net and Medical Hardship.
DHH will:a) Provide information about the full range of programs, including Mass Health,the premium assistance payment program operated by the Health Connector,

Page: 11b) the Children’s Medical Security Program, Health Safety Net, Medical Hardshipand Sliding Fee discount program;c) Help individuals complete a new application for coverage or submit a renewal
for existing coverage;d) Work with individuals to obtain all required documentation;e) Submit applications or renewals (along with all required documentation);f) Interact, when applicable and as allowed under the current system limitations,with the Programs on the status of such applications and renewals;g) Help facilitate enrollment of applicants or beneficiaries in Insurance Programs;andh) Offer and provide voter registration assistance.
DHH will advise patients of their obligation to timely provide DHH and the applicablestate agency with accurate information regarding their full name, address, telephone
number, date of birth, social security number (if available), current insurance coverage
options (including home, motor vehicle, and other liability insurance) that can cover thecost of the care received, any other applicable financial resources, and citizenship andresidency information. This information will be submitted to the state as part of theapplication for public program assistance to determine coverage for the services provided
to the individual.
If the individual or guarantor is unable to provide the necessary information, DHH may (atthe individual’s request) make reasonable efforts to obtain any additional information fromother sources. Such efforts include working with individuals, when requested by theindividual, to determine if a bill for services should be sent to the individual to assist withmeeting the one-time deductible. This will occur when the individual schedules services,during pre-registration, upon discharge checkout, or for a reasonable time following checkout from DHH. Information that patient services obtains will be maintained in accordancewith applicable federal and state privacy and security laws.
DHH will also notify the patient during the application process of the patient’s
responsibility to report to both DHH and the state agency providing coverage of healthcare
services any third party that may be responsible for paying claims, including a home, auto,or other insurance liability policy. If the patient has submitted a third party claim or filed
a lawsuit against a third party, the patient accounting department will notify the patient of
the requirement to notify the provider and the state program within 10 days of such actions.
The patient will also be informed that the patient must repay the appropriate state agency
for the amount of the healthcare covered by the state program if there is a recovery on theclaim, or the patient must assign rights to the state to allow the state to recover its applicableamount.
When the individual contacts DHH, DHH will attempt to identify if an individual qualifies
for a public assistance program or DHH’s financial assistance program. An individual who

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is enrolled in a public assistance program may qualify for certain benefits. Individuals may
also qualify for additional assistance from DHH’s financial assistance program based on
the individual’s documented income and allowable medical expenses
Responsibility:
Financial Counselor Manager
Director of Patient Access Operations
Chief Financial Officer
Forms:
None

This policy has been reviewed, approved and adopted by the Governing Board andAdministration as attested to by the signatures below:

3/16/2023
Michelle Nadow
President and CEO

Date

3/16/2023
Megan Sonderegger
Governing Board Chair

Date