(Recorded Webinar) Part V: Minimizing Financial Barriers to Care While Maximizing Revenue
PART V: Sliding Fee Discount Program and Billing & Collecting
On Part V of the De-Mystifying the Compliance Manual webinar series, we will address the health center program requirements for maximizing revenue while simultaneously minimizing financial barriers to care, and the delicate balance between the two. This webinar will introduce key elements of compliance for:
- Billing and Collection, including development of the fee schedule; billing of and collection from third party payors and patients; waiver and reduction policies to ensure access to care; and optional collection mechanisms such as prompt/cash payment discounts.
- The Sliding Fee Discount Program (SFDP), including application of the SFDP to all in-scope services including services provided by contract and by referral; development of the discount schedule; eligibility and verification processes; notification of patients; and evaluation of the program.
This webinar will focus on topics from the following chapters of the Compliance Manual:
- Chapter 9: Sliding Fee Discount Program
- Chapter 16: Billing and Collections
In the past few years, HRSA has transitioned its compliance efforts from requiring FQHCS to utilize multiple guidance documents to ensure adherence to health center program requirements to issuing the Health Center Program Compliance Manual (the Manual), a consolidated resource to assist FQHCs in understanding, demonstrating, and operationalizing compliance. The Manual, which supersedes most (but not all) prior guidance, incorporates a new approach to everyday compliance.
To assist in conducting a “hands-on” compliance evaluation, HRSA issued a Site Visit Protocol (the SVP), which aligns with the Manual and reflects a more objective assessment tool than prior review guides. The current SVP (issued in April 2019), includes additional clarification on documentation requirements and assessment methodologies.
Together, the Manual and the SVP are the main tools used by HRSA for both on-site reviews of grantees and FQHC look-alike entities (Operational Site Visits - OSVs) and “desk audits” of project and designation renewal applications, by addressing:
- Each requirement’s statutory and regulatory basis
- Key elements of compliance that form the framework of every health center’s project
- Documentation necessary to verify compliance (both on paper and in practice)
- Areas where health centers maintain discretion
There is an expectation of 100% ongoing compliance with the Health Center Program Requirements. Is your health center prepared to meet this challenge? Given the possible consequences of non-compliance, including 1-year project periods for non-compliance with a single element and potential loss of 330-grant funds, it is critical that every health center be and remain vigilant, whether you are expecting an OSV, submitting a grant or look-alike designation application, or looking to bolster current operations and establish your HRSA compliance workplan as part of ongoing compliance efforts.
- Health Center Executive Staff
- Financial Leadership and Staff, including billing and collection staff
- Administrative/operations leadership and staff
- Clinical Leadership
- Compliance Officers
- Board members
- Other Staff assisting with HRSA compliance and/or OSV preparation
After this webinar series, you will be able to:
- Describe the various elements of the Sliding Fee Discount Program and how to apply them to your specific health center project.
- Discuss the elements of billing and collection and the importance of the phrase “no margin, no mission.”
- Assess whether your current SFDP and billing and collection policies and procedures meet current HRSA requirements.
- Identify whether your current Form 5A-related contracts and MOUs are compliant with the HRSA requirements related to the application of the SFDP.
A Partner at the firm, Marcie specializes in health care law, particularly in the areas of federal grants, grant-related requirements and grants management related to the federal health center program. Health centers turn to Marcie as a resource for knowing not only the letter of the law, but also the likely interpretation of requirements by federal policymakers, including the Health Resources and Services Administration (HRSA). [Full Bio]
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