Background:
SHWC previously lacked a formal sliding fee discount schedule (SFDS) policy specific to pharmacy services. Additionally, two non-pharmacy encounters failed to receive appropriate SFDS adjustments due to procedural errors when Proof of Income (POI) was submitted post-visit.
Pharmacy-Speci...
Background:
SHWC previously lacked a formal sliding fee discount schedule (SFDS) policy specific to pharmacy services. Additionally, two non-pharmacy encounters failed to receive appropriate SFDS adjustments due to procedural errors when Proof of Income (POI) was submitted post-visit.
Pharmacy-Specific Corrections
Implemented Policies and Tools:
• PH-113: In-House Pharmacy Sliding Fee Policy
o Establishes a six-tier SFDS structure compliant with HRSA guidelines.
o Applies consistent pricing formulas and automated EHR-driven tier adjustments.
o Ensures access for all eligible patients, including those >200% FPL.
o Complies with EO 14273 for critical medication pricing.
• PH-114: Co-Pay Assistance Policy
o Standardizes process for helping insured patients with unaffordable copays.
o Uses a centralized pharmacy calculator and dual pricing logic (SFS Match, HCDRC).
o Captures patient declarations via PH-113-F104 form and documents in EHR.
Monitoring & Training:
• Staff training on new workflows and tools.
• Weekly and quarterly audits (e.g., price code validation, override reports, EHR cross-checks).
• Pharmacy SFS policies now included in SHWC’s annual HRSA sliding fee review.
Non-Pharmacy Corrections
Revised Post-Visit POI Handling:
• POI submitted after the visit must now be routed directly to the Billing Supervisor, who will:
o Scan documents into the chart
o Assess for SFS eligibility
o Apply retroactive adjustments as appropriate
Compliance Oversight:
• The Compliance Officer will audit post-visit SFS adjustments, address documentation issues, and provide staff training as needed.
Anticipated Completion Date: All corrective actions, policies, and audit mechanisms were implemented by July 31, 2025.
Responsible Individuals: CFO, Pharmacy Director, Pharmacy Staff, Billing Supervisor, Compliance Officer, Registration Staff