This is the fifth article of our FQHC requirements series covering the requirements of the Health Center Program. This program is regulated by the Health Resources and Service Administration (“HRSA’).
To folks managing Federally Qualified Health Centers (“FQHCs”), those two words have a way of keeping them up at night. And regardless of whether they are prepared for the visit, just knowing that HRSA, or the “Feds” as they are affectionately known as, will be knocking on their facility doors can be downright stressful. So, does the FQHC you manage understand and comply with the 18 program requirements? In this article we touch on the sliding fee discount program (“SFDP”) requirement by delving into its main requirement and outlining how to demonstrate compliance with it. (Note: In 2017, Health Center Program Compliance Manual, released by HRSA revised the program replacing the original 19 requirements with 18 covering 21 chapters.)
Before addressing the SFDP requirement let’s understand the purpose of a site visit. A site visit is simply oversight of the Health Center Program. This is done by assessing operational areas including fiscal, clinical and administration & governance of health centers participating in the Health Center Program. Health centers are community-based and patient-directed organizations that deliver high-quality primary health care services to the Nation’s most vulnerable individuals and families.
At the heart of the SFDP program’s requirement is eligibility. A FQHC must have a system in place in determining sliding fee eligibility. The key factors in determining eligibility are identifying the patient’s income level and their family’s size. Once those factors are identified they are applied to the sliding fee schedule and charges are determined on the basis of the patient’s ability to pay. Prior to that however, the FQHC must have a schedule of fees for the provisions of its services consistent with locally prevailing rates, designed to cover its reasonable costs of operation. In addition the FQHC must prepare a corresponding schedule of discounts (SFDP). The sliding fee schedule is set by using Federal Poverty Guidelines (“FPG”). FPG is the simplification of the poverty thresholds, and is used when determining financial eligibility for certain Federal programs. The guidelines reflect annual income levels below which a person or family is considered to be living in poverty, and the amounts increase according to the size of the family. The guidelines are updated annually by HHS (Health and Human Services).
So now that we understand how eligibility is determined, demonstrating compliance is the next step. And this step is where the folks managing FQHCs can start taking the fear out of a “Site Visit.” To demonstrate compliance with this program requirement the FQHC must meet the following (as noted in Chapter 9 of the HRSA Health Center Program):
- The Sliding Fee Discount Program (“SFDP”) applies to all required and additional health services within the HRSA approved scope of project.
- A board-approved policy for its SFDP that apply across the board to all patients.
- SFDP provides a full discount for those with annual incomes at or below the current FPG, a partial discount for those above 100% of current FPG and at or below 200% of current FPG and no discount for those above 200% of FPG.
- Discounts offered by formal referrals must be equivalent to or greater than their SFDP.
- A system, including maintaining records, for assessing/re-assessing all patients for income and family size consistent with board-approved SFDP.
- Mechanisms to inform patients of the availability of the SFDP.
- Process of evaluating the SFDP at least once every three years.
- Incorporating the most recent FPG.
To reduce the anxiety from the inevitable “Site Visit”, the FQHC must have a complete understanding of the program’s requirements and demonstrate compliance with those requirements.
Author: William R. McClusky, CPA | [email protected]
How Can We Help?
