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January 06, 2018 12:00 AM

Charity care spending flat among top hospitals

Tara Bannow
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    The yearslong decline in free or discounted care that hospitals provide to patients may have reached its floor.

    The 20 largest U.S. health systems dedicated 1.4% of their collective operating revenue in fiscal 2016 to charity care—about the same as the previous year, a Modern Healthcare analysis of financial data shows. That's noteworthy considering the significant declines in charity care spending that followed the 2014 implementation of the Affordable Care Act, a law credited with insuring nearly 24 million people through expanded Medicaid eligibility and subsidized commercial plans. Total uncompensated care fell to a 25-year low in 2015 and held steady in 2016, according to the American Hospital Association.

    What the biggest health systems spend on charity care
    Charity care as % of operating revenue
    -->
    % %
    Tax status
    public
    not for profit
    for profit
    *Premium revenue subtracted from operating revenue.
    **Tenet revenue excludes Conifer and USPI.
    Sources: Hospital financial statements and Securities and Exchange Commission filings

    THE TAKEAWAY

    Charity care spending among the country's 20 largest health systems was flat between 2015 and 2016 following years of decline, which could be partly driven by government pressure on not-for-profits.

    But the ACA did more than change the patient mix. It ushered in an era of heightened federal pressure on not-for-profit health systems to prove that they deserve their tax-exempt status. The IRS last year took the rare step of revoking tax-exempt status for two hospitals after it determined one hadn't fully implemented or publicized a required community needs assessment and the other was being operated by a for-profit company. Congress also threatened to end tax-exempt financing.

    And the ongoing tension between managing bad debt, charity care and overall community benefits may be worsening with the dilution of the ACA. Congress' elimination of the health insurance tax penalty last month could cause the uninsured rate to creep back up, which could result in more patients being unable to pay their bills.

    "We're in an environment now where uncompensated care, which had been going down, is likely to be going up," said Steve Burrill, U.S. healthcare providers leader and vice chairman for Deloitte Consulting.

    All that has some experts wondering whether not-for-profit health systems are finding ways to inflate their charity care levels, given that charity care spending stopped falling so abruptly between 2015 and 2016.

    "I'm sure there is a lot of playing around with the numbers," said Cynthia Woodcock, executive director of the Hilltop Institute, a nonpartisan health research organization at the University of Maryland.

    The federal government doesn't require not-for-profit hospitals to provide a certain amount of free or discounted care. They have since 2009, however, had to report community benefit spending to the IRS, broken down by charity care, the cost of unreimbursed Medicaid care and community improvement programs. The IRS doesn't consider bad debt—unpaid bills hospitals anticipate they won't collect on—a community benefit. Both for- and not-for-profit hospitals incur bad debt.

    Experts say some not-for-profit hospitals may now be classifying a portion of bills that previously would have been bad debt as charity care, a maneuver that merely entails not pursuing payment on bills. That lets hospitals report more charity care while simultaneously lowering bad debt. A high level of bad debt can hurt a system's credit rating.

    "Hospitals are better off not trying to recover any of the debt that they would have tried to recover before and not make a deal," said Jill Horwitz, a University of California at Los Angeles law professor and associate director of UCLA's Center for Law and Economics.

    Hospitals are seeing a significant number of patients enrolled in high-deductible health plans who are unable to pay their portion of the bills, which could also explain why uncompensated care is no longer declining, said Ashley Thompson, the AHA's senior vice president for policy analysis.

    Whether a state expanded Medicaid eligibility under the ACA also has a big effect on how much charity care its hospitals provide. Medicaid reimburses at below commercial rates, so hospitals tend to lose money on Medicaid patients. A recent AcademyHealth study of 1,700 hospitals found that while uncompensated care post-ACA declined by 25%, Medicaid shortfalls increased by 15%.

    Representatives of the top charity care providers as a percentage of revenue—not-for-profits Adventist Health System and Baylor Scott & White Health—both pointed to the lack of Medicaid expansion in their states as part of the reason their levels are so high.

    Altamonte Springs, Fla.-based Adventist, a not-for-profit system with 45 hospital campuses in nine states, is the top nonpublic charity care provider as a percentage of operating revenue. Adventist provided $316 million in charity care in fiscal 2016, 3.3% of its $9.7 billion in operating revenue. That was relatively unchanged from its 2015 charity care spending.

    Mike Griffin, Adventist's vice president of advocacy and public policy, attributed the system's standing to the fact that Florida, where 26 of the system's hospitals are located, has one of the country's highest uninsured rates because Medicaid wasn't expanded.

    Next is Dallas-based Baylor Scott & White Health, which provided about $242 million in charity care in fiscal 2016, or 3.2% of its $8 billion in revenue. Julie Smith, a spokeswoman for the system, wrote in an email that Texas also did not expand Medicaid and thus has some of the largest uninsured populations in the country. "We remain committed to meeting the needs of the communities we serve including providing access to care for both financially and medically indigent patients," she said.

    The top charity care provider, at 6.32% of operating revenue, was New York City Health & Hospitals, whose unique public operational structure naturally triggers higher charity care levels. Unlike most private hospitals, NYC Health & Hospitals receives funding from the city and state to care for low-income patients.

    Meanwhile, in California, which embraced Medicaid expansion and promoted coverage through subsidized plans, several not-for-profit systems ranked at the bottom in charity care spending as a percentage of revenue. Sacramento-based Sutter Health provided the second-lowest amount of charity care as a percentage of revenue in Modern Healthcare's analysis of 2016 data: $51 million on $10.7 billion in revenue, or 0.48%. Grace Davis, the system's chief external affairs officer, said in an email that Sutter saw a sharp increase in Medicaid patients following the ACA, resulting in a $400 million Medicaid shortfall in 2016, when California reimbursed 68 cents for every dollar spent providing care.

    Just ahead of Sutter is Oakland-based Kaiser Foundation Hospitals, which dedicated $178.4 million, or 0.74% of its 2016 operating revenue, to charity care. Kaiser Foundation Hospitals' $24.3 billion in revenue made it the second-largest system on Modern Healthcare's list.

    Dr. Bechara Choucair, Kaiser Permanente's chief community health officer, wrote in a statement that Kaiser is unique in that it's an integrated system with both hospital and health plan segments. Those segments invested a combined 3% of 2016 operating revenue in programs that benefit low-income patients and promote healthier communities.

    Ahead of Kaiser was the University of California Health System, which spent 0.75% out of $10.4 billion in operating revenue on charity care in 2016. A UC spokesperson did not return a request for comment.

    Providing the least amount of charity care among the 20 largest systems was Franklin, Tenn.-based Community Health Systems. The financially struggling for-profit provided 0.35% of its $18.4 billion in operating revenue as charity care in fiscal 2016. That's about the same level as 2015, when operating revenue was $1 billion higher. In an email, a CHS spokeswoman, emphasized that not-for-profit systems might classify the same bills as charity care that CHS classifies as bad debt.

    Modern Healthcare's review included the 20 largest for-profit, not-for-profit and public systems by operating revenue.

    Some advocates are encouraging hospitals to redirect the money they're no longer spending on charity care to programming that benefits their communities, such as health education classes and screenings.

    As hospitals' financial situations become more tenuous, they'll have more of an incentive to make sure the community from which they derive their patient population is healthy, said Dr. Georges Benjamin, executive director of the American Public Health Association. "The risk of taking care of that person is so much less," Benjamin said. "You put all that together, the concept of reaching out into the community and making fundamental change in that community knowing that is what's going to keep those people healthier makes so much more sense."

    The Hilltop Institute is developing a tool on its website that will allow visitors to search for data on hospitals' community benefit programming, such as the number of programs related to obesity and the community initiatives a certain hospital has launched. The organization also hopes to develop dashboards that will offer hospitals data from their respective states on public health issues, uninsured rates and Medicaid coverage.

    Sen. Chuck Grassley (R-Iowa) has been an outspoken critic of the standards for not-for-profit hospitals' to qualify for tax-exempt status. In a September 2017 op-ed in STAT News, he said the IRS has reviewed the tax-exempt status of 968 hospitals and referred 363 for further examination, as was required under the 2009 law that enhanced community benefit reporting. "For the provisions to have the positive effects that Congress intended, hospitals need to know that consequences exist for failing to comply," he wrote.

    Given the leeway hospitals have in how they classify, provide and report on charity care, it's unclear whether hospitals ranking low on the list provided less care than others or perhaps were more accurate with their data.

    Woodcock, of the Hilltop Institute, said some systems, such as HCA, use their gross charges, which are higher than the cost of delivering care, to report on tax forms how much they lost treating Medicaid patients.

    Some experts, herself included, question how real those numbers are. "It's almost like it's artificial spending," she said. "They're not really putting real dollars out in the community for community health improvement or population health, as some of us would like to see, but instead they're just on paper showing, 'Oh, we have more Medicaid shortfall.'"

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