(Recorded Series) The Sliding Fee Discount Program: Updates and Developments

Recorded in: August 2023

One of the foundational tenets of the Health Center Program, which dates back to the program’s inception, is the assurance by each health center that no patient will be denied services due to an individual's or family’s inability to pay for such services. The design, development and implementation of an effective Sliding Fee Discount Program (SFDP) is vital to meeting this core requirement. While the fundamental components related to SFDP eligibility have remained relatively stable throughout the years, several factors (e.g., the addition of new “required” elements by the Health Resources and Services Administration (HRSA); health centers’ expansion of their scopes to include complex services and treatments) have led to a greater degree of difficulty in establishing a SFDP that is reasonable, effective and compliant, while achieving the overall goals of minimizing financial barriers and ensuring access to care. Changes in how some health centers approach the SFDP in the wake of the recent COVID-19 pandemic have also resulted in additional layers of complexity.

This 3-part webinar series will provide a brief introduction to the HRSA-required SFDP elements, as set forth in the Health Center Program Compliance Manual, along with targeted advice and tips on development and application of the SFDP to complicated and multi-faceted services. Participants will explore aspects of the SFDP that present the most common areas of difficulty in design and implementation and that lead to highest risks of non-compliance.  

Target Audience

  • Health Center executive staff
  • Financial leadership and staff, including billing and collection staff
  • Administrative/operations staff
  • Compliance officers
  • Contracting personnel
  • Other staff assisting with the development and implementation of the Sliding Fee Discount Program

Learning Objectives

After this webinar series, you will be able to:

Part 1: The Basics - SFDP 101

  • Understand the purpose of the SFDP and the latest federal approaches to determining SFDP compliance;
  • Identify the basic HRSA-required SFDP elements and the elements that pose the greatest risk of non-compliance; and
  • Analyze whether your health center’s general SFDP policy and operating procedures meet current federal requirements.

Part 2: Applying the SFDP to Contracted and Referred Services and Establishing Discounted Cost-Sharing, Waivers and Reductions

  • Identify SFDP-related provisions (and alternatives) to ensure the availability of discounts for services provided by contract and referral;
  • Analyze whether the health center’s contracts and referral agreements meet current Federal requirements; and
  • Establish compliant waiver / reduction procedures in addition to the SFDP.

Part 3: 

  • Understand the application of and identify compliance risks related to the SFDP in the context of diagnostic and complex services;
  • Understand the application of and identify compliance risks related to SFDP in the context of drugs and contract pharmacies; and
  • Analyze whether the health center’s arrangements and policies for diagnostic services, complex services and pharmacy meet current Federal requirements.
Course summary
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Michael Glomb

Michael Glomb is a Partner in the firm's federal grants and health care groups, and has over three decades of experience advising community-based organizations on a broad range of legal matters. Specifically, he offers guidance to Federally Qualified Health Centers, other federal grantees, and several professional and trade associations on the 340B drug discount program, tax exemption, grants law, and fraud matters. [Full Bio]

Marcie Zakheim

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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