Can Medicaid denials be included in financial assistance policies

Question: Can denied Medicaid claims be reported as community benefit? I know Medicaid co-pays written off by the hospital can be counted as financial assistance if the financial assistance policy (FAP) so states.

Recommendation: If the patients in question truly are Medicaid eligible when the services were provided (in other words, ineligibility is not the reason why the denials have happened), if the services are “medically necessary” (most FAPs now say that they apply to medically necessary services - thanks to 501(r)), and if their FAP includes a clause that financial assistance is granted for these services on a presumptive basis (perhaps along with other types of presumptive assistance), then “yes.”

(January 2019)
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