Health Centers: Ensure Your Sliding Fee Discount Schedule Reflects 2018 New Poverty Guidelines
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. As it relates to health centers, the Health Resources & Services Administration (HRSA) requires centers to provide a sliding fee discount schedule (SFDS) based, in part, on the patient’s income relative to the poverty guidelines 1. In addition, centers must prepare schedules of fees or payments for center services consistent with locally prevailing rates or charges. This is 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.
The HRSA Health Center Program Compliance Manual Policy, published in December 2017, supersedes PIN 2014-02, Sliding Fee Discount and Related Billing and Collections Program Requirements, with Chapter nine (9), Sliding Fee Discount Program. The requirements, demonstrating compliance and related considerations sections, further clarify 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 their policies and procedures. They must also implement operating procedures to ensure compliance and avoid findings during HRSA on site visits.
In recent federal single audits and HRSA operational site visit reports, CohnReznick has noticed an increasing number of instances where health centers 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 (charges for services) to ensure your fees are based on your current costs and/or current prevailing market rates.
For more information, please contact Peter Epp, Partner, Healthcare Industry Practice, at firstname.lastname@example.org or 646-254-741, Dolores Di Re, Senior Manager, Healthcare Industry Practice, at email@example.com, or your CohnReznick audit partner.
1 (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))
This has been prepared for information purposes and general guidance only and does not constitute professional advice. You should not act upon the information contained in this publication without obtaining specific professional advice. No representation or warranty (express or implied) is made as to the accuracy or completeness of the information contained in this publication, and CohnReznick LLP, its members, employees and agents accept no liability, and disclaim all responsibility, for the consequences of you or anyone else acting, or refraining to act, in reliance on the information contained in this publication or for any decision based on it.