California hospitals must meet additional requirements of the Hospital Fair Pricing Act. Governor Gavin Newsom approved Assembly Bill No. 2297 (AB 2297) in September 2024 which mandates that all California hospitals comply with the additional requirements.
These changes may necessitate updates to hospitals' policies, financial assistance applications, and debt collection procedures.
If revisions were needed, hospitals must have submitted the updated documents, along with redlined versions, to the Department of Health Care Access and Information (HCAI) by January 1, 2025. Failure to have complied may result in fines for hospitals.
These new requirements follow Assembly Bill No. 1020 (AB 1020), signed by Newsom in 2021 adding even more specificity to the regulations.
Key elements have been in effect since January 1, 2022.
New key requirements are in effect as of January 1, 2025. Hospitals or emergency physicians will now be prohibited from:
Other changes in AB 2297 include:
This is not an exhaustive list of all requirements set in Assembly Bill 2297.
The Hospital Fair Billing Program enforces the Hospital Fair Pricing Act. As of January 1, 2024, responsibility for enforcement transferred from California Dept of Public Health (CDPH) to HCAI. HCAI has been diligently auditing the submitted hospital policies for violations and issuing letters for noncompliance in 2024.
Due to the lag time of HCAI’s review of hospitals' policies on the HCAI website, hospitals may receive notice from HCAI significantly after the reporting deadline and should be ready to quickly respond.
Penalty assessments range from $12,500 per moderate violation to $25,000 per major violation. Multiple violations can be applied per policy as well as a $500 per day penalty for noncompliance.
Hospitals won’t be provided an estimated amount or assessed the penalty until all violations are corrected.
To learn more about these requirements and other revenue cycle issues, contact your Moss Adams professional.
Assurance, tax, and consulting offered through Moss Adams LLP. ISO/IEC 27001 services offered through Moss Adams Certifications LLC. Investment advisory offered through Moss Adams Wealth Advisors LLC. Services from India provided by Moss Adams (India) LLP.