Some hospitals failed to train all patient access employees on the new 501(r) requirements for financial screening, reports Holly Lang, a New York City-based contractor specializing in healthcare financing, public policy analysis, and nonprofit hospital strategy.

“A fully compliant policy is only as good as its execution,” Lang says. “Unfortunately, we’ve seen a lot of hospitals fall short in this respect.”

Here are some practices that can put patient access out of compliance with 501(r) requirements:

  • Failing to provide hard copies of the financial assistance policy, and failing to display the application prominently.

“While the decisions about displaying information are probably made by hospital leadership, front line patient access staff still need to know that patients will be looking for this information — and have a right to get it,” says Jessica Curtis, JD, senior advisor of the Hospital Accountability Project at Boston-based Community Catalyst.

The law requires hospitals to construct “conspicuous” public displays about financial assistance in the ED and admissions.

“It’s the law now that each patient get a ‘plain language summary’ of the financial assistance policy to take home with them at either intake or discharge,” Curtis adds.

  • Patient access notes accounts if a patient expresses a need for financial assistance, but it doesn’t drive a specific workflow.

David Figueredo, business development manager for revenue optimization services at Change Healthcare in Nashville, TN, says, “Successful organizations will identify that the patient requested financial need, and there will be a key indicator in the comments to drive that account into a specific work queue.”

  • Inconsistent processes for how and whether patients receive information about financial assistance.

Patients should be alerted that financial assistance may be available at every date of service. “This sounds like extra work,” Curtis acknowledges. “But it’s really about making these conversations routine so everyone can avoid problems later.”

  • Failing to share financial assistance information because patient access “knows” that a particular patient is ineligible.

Curtis suggests viewing financial assistance screening the same way as patient privacy requirements: “something that is just part of the conversation they have with patients at every visit.”

  • Staff conducts financial assistance screening inconsistently across various entry points.

The ED may feature a strong financial assistance screening program, for instance, but hospital clinics or other entry points don’t. Figueredo notes, “Often, it is not a lack of policy that causes this.” Staff don’t always follow existing policies.

Sandra J. Wolfskill, FHFMA, director of healthcare finance policy at the Westchester, IL-based Healthcare Finance Management Association, agrees: “Too often, patient access makes financial assistance the solution of last resort — or doesn’t even mention it at all.”

  • Patient access staff pressure uninsured or underinsured patients to make a payment or accept a payment plan solution.

Doing so if a patient indicates, even subtly, that financial assistance is needed, says Wolfskill, “creates an opening for noncompliance allegations.”


  1. Rosenbaum S. Additional requirements for charitable hospitals: Final rules on community health needs assessments and financial assistance. Health Affairs Blog, Jan. 23, 2015. Available at:


  • The Healthcare Finance Management Association’s Patient Financial Communications Best Practices for pre-service, the ED, and outside the ED, available at:
  • Community Catalyst’s Hospital Financial Assistance Policies: A Quick Reference Guide, available at: