Dear Colleagues:

Many changes have been and will be made to the free care regulations in Massachusetts, some of which have institutional and provider impacts. As of January 1, hospitals may submit claims to the Free Care Pool for Critical Access Services only. This is an important change that could have an impact on a significant amount of BWH patients.

Currently, approximately 2,000 patients eligible for free care seek their primary care at Brigham Internal Medicine Associates (BIMA) and other hospital-affiliated practices. With the new regulations, primary care services are not considered critical access services and will no longer be reimbursed by the Free Care Pool. However, certain exceptions to this regulation are allowed. These include:

1. there is no community health center within five miles of the hospital at which the patient is seeking primary care; and
2. the patient’s acuity would not allow for his or her primary care to be adequately provided in a community setting.

Under the leadership of BIMA Medical Director Phyllis Jen, MD, a survey will be completed for each of the 2,000 free care patients in the practice. The results of the survey will help gather more information on how to better identify those free care patients who must remain at BIMA for primary care. BWH will share the results of these surveys with the State in an effort to help clarify the exemption criteria related to acuity and to provide information on the impact of the regulatory changes.

While BWH moves forward to comply with the new free care regulations, much care is being taken to not compromise patient needs. Specifically, the access to specialty services and pharmacy services of those patients deemed non-eligible for free care at BWH is being examined. Through the leadership of Elizabeth Glaser, vice president, Clinical Services, a comprehensive Steering Group and several subcommittees have been assembled to specifically address such issues.

Sincerely,

Andy Whittemore, MD
Chief Medical Officer