In the attached public record Atrium, through its General Counsel's office, informs CMS auditor Stephen Wood of PalmettoGBA of Atrium's 'No Pay' policy (see page 6).

​

Of note is this statement (from page 6) from Atrium to CMS in 2022 concerning their 'No-Pay' policy with MedCost:

"So, when CMHA ['Atrium'] employees receive services from an [sic] CMHA hospital or other health care provider, instead of CMHA billing and paying itself, MedCost processes these claims as "No-Pay" claims and CMHA transfers money internally. MedCost follows a similar process for other health care provider clients that are self-insured. CMHA sets rates the "No-Pay" claim services [sic] as a discount from charges and ensure [sic] that such rates are not more than the rates commercial plans pay, such as Blue Cross Blue Shield, would pay. Then, CMHA transmits those rates to MedCost."

​

Recently Atrium's Board informed me that there were 'no documents' related to this policy.