MHS Modified Payment and Waiver Program: Billing Delays

Billing Delays

This page contains a series of frequently asked questions. You can use the search bar below to explore additional FAQ pages.
Q1:

Why has it taken so long to implement the FY 2023 NDAA provision to design the MPWP?

A:

We understand that receiving a bill for a service from a long time ago can be frustrating. The delay is attributable to our effort to prevent financial harm to any patient before the new, congressionally mandated protections were in place.

Section 716 of the FY23 NDAA was a landmark change in federal law. For the first time in its history, the Department of War was granted the authority to offer significant financial assistance to civilian patients. This was a major change that required us to build a new program from the ground up to comply with all legal requirements. This involved writing a new federal rule, which requires additional time to implement.

Q2:

Why haven't military hospitals or clinics been billing for the last few years?

A:

The decision to pause billing was made to ensure that no patient was billed under the previous, much more stringent, federal debt collection rules while we worked to design and implement a more compassionate authority.

Q3:

Why wasn’t my insurance billed during the delay?

A:

While most insurance claims were filed during the billing delay period, many military medical facilities transitioned to a new medical billing system. Unfortunately, in some cases a patient’s health insurance information was added to their record after the initial billing process had started. The system incorrectly continued to treat the account as "uninsured." As a result, it held the bill in abeyance instead of sending a timely claim to the insurer.

Q4:

The final rule applies to care provided on or after June 21, 2023. Does DHA intend to issue bills that were deferred during the rulemaking period?

A:

Yes. Invoices will include information about the new MHS Modified Payment and Waiver Program and how to apply.

Q5:

If deferred bills are issued, will they be recalculated under the new MPWP standards? Will patients receive retroactive application of the sliding fee scale or catastrophic waiver for care provided between June 21, 2023 and the rule’s effective date?

A:

All civilian non-beneficiaries who received care on or after June 21, 2023, may apply to the MHS Modified Payment and Waiver Program.

Once a patient receives a medical bill, if they face financial harm, they are encouraged to apply for the program. All complete applications will be evaluated based on the standards in the final rule, effectively applying the sliding fee scale and catastrophic waiver benefits.

Q6:

If deferred bills are issued simultaneously, does DHA plan to consolidate those charges into a single statement, offer extended payment deadlines, or provide structured payment plans to prevent financial hardship?

A:

To prevent financial hardship, the program includes specific, structured payment options. While bills for separate episodes of care are processed individually and will not be consolidated, patients approved for the program may have each bill discounted under the law and are guaranteed access to flexible payment plans. As established by the rule, these payment plans can extend for up to 72 months and are interest-free.

Q7:

Are any deferred balances being written off entirely?

A:

No. Per federal guidelines, financial relief is not automatic and cannot be granted preemptively. The established process requires that a medical bill first be issued. Following that, the patient must apply for financial assistance through the MHS Modified Payment and Waiver Program. A balance can only be reduced or waived after a formal application has been submitted by the patient and adjudicated by the DHA Debt Adjudication Office.

Q8:

I received treatment after June 21, 2023. Where’s my bill?

A:

For patients with health insurance, the military hospital or clinic will bill the insurer first. Patients with a remaining balance (e.g., for copayments, deductibles, coinsurance, etc.), will receive an invoice and may apply for a discount or waiver after that.

Q9:

What happens if my insurance company denies my bill for being held so long?

A:

We'll retroactively file your insurance. If it's denied for the military hospital or clinic not having filed timely, you'll only receive the portion of the bill that you would have been responsible for under your health plan limitations.