Chief Compliance and Ethics Officer Health Care

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  • 1.  Guarantors

    Posted 08-27-2018 12:49 PM
    ​Good afternoon,
    I am looking for any rules or guidance on the assignment of "guarantor" at registration for adults (without disabilities).
    The assignment of who is listed as guarantor seems to raise multiple issues for debate, mostly in privacy, cost, and likelihood of payment-
    1. when minors-turn-adult (18)  regardless if still on  parents health plan or own Medicaid recipient
    2. legal married spouse - regardless of living arrangements
    3. Our rural healthcare agency having traditionally used "family billing" practices to include extended members on one billing statement.
    Can anyone point me to the CMS or other billing rule re: assignment of guarantor and suggested documentation?
    Thank you in advance!

    Marcia Rasch PhD,CHC
    Corporate Compliance Officer
    HealthSource of Ohio
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  • 2.  RE: Guarantors

    Posted 08-28-2018 11:10 AM


    This is how we do it, per our EMR rules.

    Defining and Determining Guarantor

    • Guarantor Information is responsible party information. A Guarantor (or responsible party) is the person held accountable for the patient's bill.

    • The guarantor is always the patient, unless the patient is a minor or an incapacitated adult.

    • The guarantor is not the insurance subscriber, the husband, or the head of household.

    • A patient presenting for care that is 18 years of age or older is always the guarantor for bills relating to their care except an incapacitated adult.

    • College students 18 years of age or older are always the guarantor for services they receive.    

    • The guarantor for a minor child (a child that is under 18 years of age except for an emancipated minor) is the parent that presents the child for care at the time of the initial visit.

    NOTE: If the parent presenting child brings divorce decree stating other parent is financially responsible for the child's medical bills, guarantor is changed to the parent designated in the divorce decree.

    • The "other parent" is not the guarantor.

    • An emancipated minor is the guarantor for services they receive.



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  • 3.  RE: Guarantors

    Posted 08-29-2018 07:40 AM
    ​​Thank you so very much!
    I appreciate your sharing your protocols!  It makes so much sense!

    Marcia Rasch PhD,CHC
    Corporate Compliance Officer
    HealthSource of Ohio

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  • 4.  RE: Guarantors

    Posted 08-30-2018 09:05 AM
    State financial responsibility laws typically state both parents are financially responsible for their minor children. As a third party, you are not a party to a divorce and legally bound by that decree. In my opinion you are free to pursue either parent for those bills and it is their issue to settle between the two of them as to who has to pay per the decree. I would consult legal before developing a process that potentially excludes a subset of guarantors who are divorced.

    Brenda Manning J.D., C.H.C., C.H.P.C.
    Compliance Director, Privacy
    Carilion Administrative Services Building, Ste. 1201
    213 S. Jefferson Street
    Roanoke, VA 24011
    (540) 224-5757
    Fax: (540) 510-224-5787
    Integrity Help Line Compliance: (844) 732-6232

    Our Mission: Improve the health of the communities we serve.

    The views expressed herein are my own and do not represent those of my employer. They are not meant to constitute legal advice or create an attorney-client relationship.

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