Allina Health-wide Policy: System Wide
Collection Policy
Origination Date: January 2016
Updated Date: August 2017
Scope:
This policy applies to the collection agencies retained by any Allina Health business
office to collect medical debt from individual patients.
Purpose:
To establish a policy governing the collection of medical debt from individual patients
by collection agencies retained by Allina Health, in accordance with the guidelines
set out in an agreement with the Minnesota Attorney General’s Office and other state
and federal laws governing hospitals or clinics.
Policy:
When collecting medical debt, collection agencies will treat the patients of Allina
Health with honor, dignity, and courtesy; demonstrate compassion; and be good
stewards of health care resources. This policy establishes standards for the
fulfillment of Allina Health’s values in the collection of medical debt by collection
agencies. There is zero tolerance for abusive, harassing, oppressive, false,
deceptive, or misleading language or collection conduct by collection agencies that
collect medical debt from Allina Health’s patients. This policy supersedes all
existing policies regarding the collection of patient accounts receivable by all units
of Allina Health.
Procedures:
1. Patient Correspondence.
All correspondence seeking collection of medical debt from patients will contain
at least the following information:
a. a local or toll-free number patients may call to question or dispute bills;
b. an address to which patients may write to question or dispute bills;
c. the following information, in the same size and font as other words in the
body of the communication, regarding the Minnesota Attorney General’s
Office: “If you feel that your concerns have not been addressed, please
Page 1 of 6
This policy supersedes all prior policies of the same or similar subject except to the extent it is inconsistent with the express terms of a
collective bargaining or individual agreement.
contact our office first and allow us the opportunity to try to address your
concerns. If you continue to have concerns that have not been
addressed, you may contact the Minnesota Attorney General’s Office,
which can be reached at 651-296-3353 or 1-800-657-3787.”
2. Communications with Patients.
a. When patient responsibility is determined, the patient will receive a
monthly statement indicating the balance due and options for
resolving the balance they owe.
b. An attempt(s) will be made to contact the responsible party to resolve
their balance when the patient responsibility is aged 61 days from
the date of the initial statement.
c. During any initial contact with the responsible party regarding the
collection of medical debt, if there is a question as to whether the
person billed was the person who received the services, Allina Health
staff will verify any demographic information necessary to confirm
that the person billed actually owes the debt. Collectors will also
verify the accuracy of any information regarding third-party payers
that may be obligated to pay for medical items or services received
by the patient.
d. During any initial or subsequent contact with a patient regarding the
collection of medical debt, if the responsible party has indicated an
inability to pay the full amount of the debt in one payment, collectors
will discuss with the patient of all of the following options:
i. The responsible party may pay the balance of the debt in
twelve monthly payments or a minimum payment of $ 30.00
per month, whichever is greater, through an established
installment plan; longer installment plans must be approved
on a case-by-case basis by the manager or director of
Customer Service and Collections within the respective
business office.
ii. The responsible party may apply for free care through Allina
Partners Care Policy (referred to as the “Partners Care
Policy”).
iii. The responsible party may finance the debt through Allina
Health’s MedCredit program, which extends credit to every
Page 2 of 6
This policy supersedes all prior policies of the same or similar subject except to the extent it is inconsistent with the express terms of a
collective bargaining or individual agreement.
patient with an income regardless of the responsible party’s
past credit history (assuming no previous MedCredit default),
and will not charge interest if the balance is paid within 90
days;
e. If the responsible party desires to apply for free care, collection staff
will mail an application to the patient at the patient’s last known
address and suspend collection activity for 30 days. Collection
activity may resume if, after 30 days, an application for free care has
not been received. If the patient has submitted an application for free
care, collection activity may resume after the application for free care
has been denied or if the application has not been returned with the
requested information.
f. The collection staff will keep a record of the date, time, and purpose
of all communications with patient debtors.
g. If after a period of 120 days from the initial billing statement payment
arrangements have not been made by the responsible party and the
responsible party has not been approved for Allina Partners Care, a
final notice will be sent out indicating that payment is overdue and
needs to be resolved within 10 days of the letter or the account may
be sent to a collection agency.
h. The collection agency will send a validation notice to the responsible
party for each outstanding balance received by the agency and allow
the responsible party 30 days to dispute the balance owed.
i. If the balance remains unresolved after the 30 day validation period,
collection attempts will continue until the time the balance is resolved
by payment arrangements or the responsible party has applied and
been approved for free care through Allina Partners Care.
j. Applications for Allina Partners Care will be accepted and reviewed
for a period of at least 240 days from the date of the original billing
statement showing the balance due from the responsible party.
k. Reference to Minnesota Attorney General. At no time during the
collection process will the collection agency state or imply, either
directly or indirectly, that the State of Minnesota Attorney General’s
Office has approved of, condones, or agrees with any lawsuit,
garnishment, or other attempt by Allina Health to collect debt from a
patient/ guarantor.
Page 3 of 6
This policy supersedes all prior policies of the same or similar subject except to the extent it is inconsistent with the express terms of a
collective bargaining or individual agreement.
l. Attorney Representation of Patient/ Guarantor. If the collection
agency has knowledge of the identity of an attorney representing a
patient in connection with its debt collection efforts, the collection
agency will notify outside counsel (if applicable) of the identity of any
attorney who represents the patient/ guarantor. The collection
agency will not directly contact any patient known to be represented
by an attorney with regard to collection of that debt without
permission of the patient/ guarantor’s attorney.
3. Suspending Collections While Responding to Patient Questions or
Disputes. Allina Health will exercise its best efforts to respond to all questions
or disputes from patients regarding a medical bill as soon as possible and also
within the time frames set forth below.
a. Telephone messages should be returned within one business day from
the date of the message.
b. All inquiries should be investigated and resolved within 30 days. If an
inquiry cannot be fully resolved within 30 days, the patient should be
notified by the 30th day of the status of the inquiry and be given a
reasonable estimate of the time needed for resolution.
c. Collection activities will be suspended if a patient advises collection staff
that: a) the patient does not owe all or part of a bill; or b) a third-party
payer should pay the bill; or c) the patient needs documentation
concerning the bill. Collection activities may resume 30 days after
information has been provided to the patient confirming that the debt is
valid. All business units must have audit procedures in place to ensure
that these requirements are being met. Audit results should be
documented on a monthly basis along with any corrective action that
was needed
d. If a patient asks for an address and/or phone number of an Allina Health
business office where the debt originated, the information will be
promptly provided.
4. Patient Complaints. The collection agency will maintain a log of all oral and
written complaints received by any patient or patient representative. The log
will include, but need not be limited to, complaints defined as any
communication from a patient or patient’s representative in which they express
concerns about the conduct during debt collection of an Allina Health
employee, the collection agency, or a law firm retained to collect medical debt
Page 4 of 6
This policy supersedes all prior policies of the same or similar subject except to the extent it is inconsistent with the express terms of a
collective bargaining or individual agreement.
for Allina Health. In addition, staff will also be required to log any instances in
which the patient or patient’s representative indicates that is complaining about
price, quality of care, or the reasonableness of payment options. Staff will also
be asked to log any instances where the caller specifies that they will be
forwarding their concern to Allina Health Senior Management, the Better
Business Bureau, or the Attorney General. These complaints will be noted on
the patients account with specific note types that can be reported upon. A
summary of the complaints will be prepared on an annual basis in conjunction
with the annual review of collection activities performed by the CEO and Allina
Health’s Board of Directors. The collection agency will provide a copy of the log
to the Allina Health Law Department at least six times per year.
5. Extraordinary Collection Actions.
a. Before any debt is referred to litigation, either in conciliation court or
district court, the collection agency will verify that:
i. There is a reasonable basis to believe that the patient owes
the debt;
ii. All third-party payers have been properly billed such that any
remaining debt is the financial responsibility of the patient; and
iii. Where the patient has indicated an inability to pay the full
amount of the debt in one payment, the patient has been
advised of his or her options pursuant to Section 3(b) of this
policy and, if applicable, given a reasonable period of time to
submit an application for Allina Health’s Partner Care
program.
iv. The patient has received the plain language summary (PLS)
of the Partners Care policy.
b. The collection agency will certify to the appropriate business office
leader that the conditions identified in Section 5(a) of this policy are
satisfied. Upon receiving such certification, the business office may
authorize litigation to proceed. The collection agency will provide
information to establish that the conditions identified in Section 5(a) of
this policy are satisfied when requested by the business office leader.
The business office will not issue blanket authorizations to proceed with
litigation on all accounts referred to a collection agency.
c. If litigation has been authorized by the appropriate business office, the
collection agency may proceed in conciliation court, or refer the debt to
Page 5 of 6
This policy supersedes all prior policies of the same or similar subject except to the extent it is inconsistent with the express terms of a
collective bargaining or individual agreement.
a law firm that has a contract with the Allina Health Law Department to
collect debt on behalf of Allina Health.
6. Contracts with Collection Agencies.
a. Allina Health business units involved in the collection of medical debt will
enter into a written contract (or business memorandum) directly with any
collection agency. A collection agency retained by Allina Health to
collect medical debt is prohibited from sub-contracting with another
collection agency without prior consent from Allina Health.
b. Contracts, or business memoranda, between an Allina Health business
office and a collection agency will be reviewed annually by Allina
Health’s Chief Executive Officer following an audit of the collection
agency. In determining whether to issue or renew any contract or
business memorandum with a collection agency, the CEO will consider
whether the debt collection agency has acted in a manner consistent
with this policy and Allina Health’s agreement with the Minnesota
Attorney General’s Office, as well as Allina Health’s mission and
applicable laws.
c. Collection agencies will not receive any performance bonus, or other
similar payment which is calculated on the basis of the amount or
percentage collected from two or more patients.
d. Contracts, or business memoranda with a collection agency will contain
the following requirements:
i. Collection agencies will cooperate with an audit conducted by
the Allina Health Audit Section on an annual basis.
ii. Collection agencies will follow the practices and procedures
contained in this policy.
iii. Collection agencies will participate in training on the financial
assistance programs available to Allina Health patients.
7. Credit Reporting Prohibited. The collection agency will not report any patient
to a credit reporting agency as a result of that patient’s failure to pay a medical
bill.
Page 6 of 6
This policy supersedes all prior policies of the same or similar subject except to the extent it is inconsistent with the express terms of a
collective bargaining or individual agreement.
