The U.S. Department of Health and Human Services (HHS) released new U.S. Federal Poverty Guidelines (FPG) which are used to determine financial eligibility for certain federal programs. The 2019 HHS poverty guidelines published in the Federal Register on Feb. 1, 2019, are in effect as of Jan. 11, 2019. 

Health Resources & Services Administration (HRSA) requires health centers to provide a sliding fee discount schedule (SFDS) based, in part, on the patient’s income relative to the poverty guidelines . In addition, centers must prepare schedules of fees or payments for center services that are consistent with locally prevailing rates or charges and designed to cover a center’s reasonable costs of operation and prepare corresponding SFDS applied to the payment of its fees or payments, by which discounts are adjusted based on the patient's ability to pay.

HRSA Health Center Program Compliance Manual, updated August 2018, further clarifies center requirements including multiple discount schedules.

What does CohnReznick think?

Health Centers must adopt the requirements contained in the Health Center Program Compliance Manual into its policies and procedures and implement operating procedures to ensure compliance to avoid findings during HRSA onsite visits.

In recent federal single audits and HRSA operational site visit reports, CohnReznick has noticed an increasing number of instances where our health center clients have failed to use the current FPG. This suggests that implementation of the new guidelines may be slipping through the cracks.

Now is the time to update your SFDS to reflect the new FPG schedule. It is also a good time to review your fee schedule to ensure your fees are based on your current costs and current prevailing market rates.

Contact

For more information, please contact:

Peter Epp, Partner, Healthcare Industry Practice

(646) 254-7411

Dolores Di Re, Senior Manager, Healthcare Industry Practice

(646) 625-5703

CohnReznick is a proud corporate sponsor of NACHC and is looking forward to connecting with fellow community health center professionals and leaders at our Policy & Issues Forum booth this March in Washington, D.C.

Section 330(k)(3)(G) of the PHS Act; 42 CFR 51c.303(f), 42 CFR 51c.303(g), 42 CFR 51c.303(u), 42 CFR 56.303(f), 42 CFR 56.30(g), and 42 CFR 56.303(u) 

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