How do we evaluate whether our fee schedule is current and up to date?
The Health Center Program Compliance Manual and Site Visit Protocol, Chapter 16: Billing and Collections, Element A (Fee Schedule for In Scope Services) and Element B (Basis for Fee Schedules), requires that the health center ensures that the fee schedule uses data based on locally prevailing rates and actual health center costs to help develop and update the fee schedule. There are a number of avenues to complete the evaluation. Some health centers utilize a third party vendor which evaluates the fees for the local market and compares them to other local health care entities within the area. Other health centers compare their fee schedule to the Medicare fee schedule and then increase it by a certain percentage (example, increase fees by 80%-150% based on the health center’s costs). While there is no wrong way to review a fee schedule, it’s important to complete a thorough evaluation. The industry practice is to review the fee schedule at least once a year. If a health center reviews their fees and see that they are reasonable and in line with market rates, it’s’ important to discuss the evaluation within the finance committee and then the full governing board.
For more information on HRSA requirements, please visit: https://bphc.hrsa.gov/programrequirements/compliancemanual/chapter-16.html.
To learn more about setting fees, please visit: https://www.revelemd.com/blog/fee-schedule-dos-and-donts .
Regulators are no longer satisfied with documentation alone; they want evidence that your compliance program actively prevents, detects, and corrects risk. Investigators expect to see how issues are identified early, investigated thoroughly, corrected effectively, and monitored over time. Boards demand measurable insight, and leadership needs confidence that exposure is managed before it becomes a liability. The standard has shifted from activity to impact.