As HRSA restarts Operational Site Visits (OSVs) through the virtual process, Chapter 9-Sliding Fee Discount Program is a chapter which can cause health centers (FQHCs and FQHC LALs) a lot of headaches! Why is that? Simply put, there are so many moving elements, and getting them all together can be difficult. This blog post will focus on some areas that may help health centers review their sliding fee program.
- First, have a board approved policy. Chapter 19-Board Authority, Element D (Adopting, Evaluating and Updating Health Center Policies) requires that the Sliding Fee Discount Program (notice it says “Program”, not just sliding fee scale) be adopted, and evaluated within the last three (3) years. While the program that a health center has may not have changed, it is still a requirement to review and/or evaluate. Remember that the Federal Poverty Guidelines (FPG) are updated every year and directly affect the sliding fee scale. Since this could have an impact on what a patient would pay each year, any change to the sliding fee scale must be updated and board approved. If a health center has more than one sliding fee scale (medical, dental, behavioral health or pharmacy), all sliding fee scales need to be updated and board approved. Element B in Chapter 9-Sliding Fee Discount Program clearly lays out what is required in the policy. A best practice would be to make a “check box list” with the questions asked and compare it to your current policy.
- Second, the Sliding Fee Discount Program is based on ONLY two areas: family size and income. This means that ALL patients can apply for the Sliding Fee Discount Program; including Medicare and Medicaid recipients, or those that have other health insurance. Here is an example: Mrs. Smith has insurance, and received a medical visit that has an established fee of $80.00 per the health center’s fee schedule. Based on her insurance plan, her co-copay is $60.00 for this service. Mrs. Smith applied for the Sliding Fee Discount Program and, based on her family size and income, she is at 150% of the FPG and qualifies for the sliding fee discount program. The health center currently provides a discount of 50% for patients with an income at 150% of the FPG. Based on the discounted service, Mrs. Smith would be billed a discounted charge of $40.00. Rather than the $60.00 co-pay, the health center would charge Mrs. Smith no more than $40.00 out of pocket, consistent with their Sliding Fee Discount Program (as long as it’s not precluded or prohibited by the applicable insurance contract).
- Third and finally, Element L-Evaluation of the Sliding Fee Discount Program requires the health center to evaluate at least once every three years the program (note that it states the entire program and NOT just the sliding fee scale). How would a health center evaluate the program? A health center would want to consider various data such as patient surveys, data from the practice management system (i.e. how many patients are in each pay class/level and if there are any outstanding bills), asking patient board members that use the Sliding Fee Discount Program whether it is a barrier to their care, and so on. A health center can decide which methodology is used to evaluate the entire program. If a health center notices that the program is not being utilized as much as it should, or some areas of improvement to increase eligibility are lacking, then steps should be taken to implement new processes and provide feedback to the governing board of directors.
For a more in-depth discussion on the Sliding Fee Discount Program, please watch the October 2020 complimentary Compliatric webinar which can be found here: https://compliatric.com/continuous-compliance-chapter-9/