Alert

The North Carolina Medical Debt Relief Incentive Program, announced by Governor Roy Cooper and the North Carolina Department of Health and Human Services in July 2024, has been approved by the Centers for Medicare and Medicaid Services (CMS).

North Carolina estimates it will relieve up to $4 billion in existing medical debt, helping almost 2 million residents. All 99 North Carolina hospitals opted to participate in the program.

North Carolina providers should begin working to comply with program requirements, which become effective in stages through July 2026. Providers in other states should consider preparing to comply with similar requirements as multiple states and federal agencies are considering similar efforts.

What’s Included in the Medical Debt Relief Incentive Program?

The Medical Debt Relief Incentive Program will require hospitals to forgive eligible medical debt for Medicaid enrollees dating back to January of 2014. The program also requires participating hospitals to implement policies intended to prevent low- and middle- income residents from incurring further medical debt.

Hospitals will need to do the following:

• Provide discounts ranging from 50%–100% on medical bills, based on patient income
• Allow patients to qualify for presumptive charity care based on either income level or being a recipient of government assistance and automatically apply these discounts to patient statements
• Prohibit medical debt to be sold to debt collectors for patients with incomes at or below 300% of the Federal Poverty Level (FPL)
• Restrict interest rates on medical debt at participating hospitals at 3%
• Commit to not report medical debt to credit agencies

These requirements build upon the federal 501(r) requirements.

Important Dates

What providers should do now:

• Update charity care and collections policies to reflect the Medical Debt Relief Incentive Program requirements
• Educate revenue cycle staff and implement controls related to self-pay collection to mitigate compliance risks and monitor for compliance
• If not already in place, implement a Presumptive Eligibility solution for charity care and Medicaid
• Coordinate with regulatory reporting team to coordinate impact of this program on reports such as Medicare Cost Reports
• Bolster point-of-service collection and price transparency tools so you can provide patients with additional confidence around financial liability prior to receiving services
• Identify and establish contractual relationship with a nonprofit partner to collaborate on medical debt relief

We’re Here to Help

For further assistance in navigating the requirements set by the Medical Debt Relief Incentive Program, please reach out to Moss Adams.

Additional Resources

• Health Care Practice
• Revenue Cycle Services