In keeping with recent trends pertaining to the issuance of new policies and guidance, the Health Resources and Services Administration (HRSA) recently issued Frequently Asked Questions (FAQs) to clarify certain aspects of PIN 2014-02: Sliding Fee Discount and Related Billing and Collections Program Requirements. While some of the FAQs appear to reiterate the requirements set forth in the PIN, the document includes several important clarifications regarding, among other things, the extent of board approval, eligibility assessment, the definitions of income and family size, and discounts on supplies. In particular, the following provide additional clarification above and beyond what was included in PIN 2014-02.
- While governing boards are required to approve the Sliding Fee Discount Program (SFDP) policies that establish the foundation for the SFDP, they are not required to approve the supporting and related operating procedures.
- For purposes of Uniform Data System reporting, health centers are required to assess income and family size for all patients regardless of whether an individual patient would qualify for the SFDP and/or insurance status.
- When determining eligibility for the SFDP, health centers:
- Are not allowed to include assets in the income calculation, either as an additional threshold or as part of a “net worth” calculation.
- Can include as part of “family size” persons who are not living with the patient but who are largely dependent on the patient’s income.
- Health centers have flexibility to establish charges for service-related supplies and materials (such as eyeglasses, dentures, etc.) that are greater than a full slide, provided that the charge is less than the “locally prevailing charge” for the item and this discount facilitates patient access.
Additionally, the FAQ document clarifies that the SFDP requirements apply equally to Health Care for the Homeless (Section 330(h)) programs; thus, HCH programs must establish fee and sliding fee discount schedules similar to those established for other populations. Nevertheless, health centers retain flexibility in establishing the related operating procedures to minimize barriers to care.
HRSA noted that new FAQs will be added as necessary. Accordingly, Primary Care Associations and health centers are encouraged to continue submitting questions and requests for clarification to HRSA. For additional information on PIN 2014-02, please see the Policy Shop blog from October 7, 2014, entitled “HRSA Issues Much Anticipated Sliding Fee Discount Program Policy.”