Finding Text
Health Center Program Cluster – Assistance Listing Numbers 93.224 and 93.527
U.S. Department of Health and Human Services
Award No. 6 H80CS04286-19, April 1, 2023 – March 31, 2024
Award No. 6 H80CS04286‐20, April 1, 2024 – March 31, 2025
Award No. 6 H8FCS41015‐01, April 1, 2021 – March 31, 2024
Award No. 6 H8GCS47983‐01, December 1, 2022 – December 31, 2023
Award No. 5 H8HCSHealth Center Program Cluster – Assistance Listing Numbers 93.224 and 93.527
U.S. Department of Health and Human Services
Award No. 6 H80CS04286-19, April 1, 2023 – March 31, 2024
Award No. 6 H80CS04286-20, April 1, 2024 – March 31, 2025
Award No. 6 H8FCS41015-01, April 1, 2021 – March 31, 2024
Award No. 6 H8GCS47983-01, December 1, 2022 – December 31, 2023
Award No. 5 H8HCS45036-02, September 1, 2022 – August 31, 2023
Award No. 1 H8ICS46994-01, September 1, 2022 – August 31, 2024
Award No. 1 H8LCS51874-01, September 1, 2023 – December 31, 2024
Criteria or Specific Requirement – Special Tests and Provisions: Sliding Fee
Discounts (42 USC 254(k)(3)(g); 42 CFR sections 51c.303(g); and 42 CFR sections
56.303 (f))
Condition – Sliding fee discounts applied to patient charges were inconsistent with
the Organization’s sliding fee discount schedule. The Organization’s sliding fee
discount policy is not compliant with the Health Center Compliance Manual for
dispense fees of its in-house pharmacies, which are within the scope of the Health
Center Program.
Cause – The Organization did not comply with its sliding fee discount policy. The
Organization also expanded it’s in-house pharmacy services in recent years without
ensuring the informal policy and information system were set up in compliance with
the Health Center Compliance Manual.
Effect or potential effect – The patients’ responsibility for services rendered by the
Organization was inconsistent with the sliding fee discount schedules. Additionally,
the Organization’s sliding fee discount schedules for in-house pharmacy dispense
fees did not contain the required number of categories between 100% and 200% of
the federal poverty levels (FPL) or differentiate dispense fees based on FPL for
certain prescription drugs. Further, not all patients of the Organization’s in-house
pharmacies were given the opportunity for the sliding fee discount program.
Questioned costs – None
Context – The population of sliding fee discounts was stratified between in-house
pharmacy dispense fees and all other in-scope services of the Organization. A
sample of 25 prescriptions were tested out of a population of approximately 52,000
prescriptions dispensed through the in-house pharmacies and 7 instances of
inappropriate sliding fee discounts were identified. A sample of 25 encounters were
tested out of the population of approximately 146,000 encounters for all other inscope
services and 2 instances of inappropriate sliding fee discounts were identified.
The sampling methodology used is not and is not intended to be statistically valid.
Additionally, the Organization’s informal policy for sliding fee discounts of in-house
pharmacy dispense fees contains 2 categories instead of the minimum of 3 between
100% and 200% of the FPL. The Organization also maintains 2 lists of prescription
drugs that are dispensed for a flat dispensing fee if covered under the 340B
program, rather than applying discounts based on the patient’s ability to pay. Finally,
the Organization only offers sliding fee discounts on prescriptions that also qualify
under the 340B program.
Identification as a repeat finding, if applicable – No.
Recommendation – The Organization should review the sliding fee discount policy
and schedules to ensure compliance with the Health Center Program Compliance
Manual for all services within the scope of the program while considering
improvements that can be made to improve compliance with the policy and
schedules and increased accuracy of system-generated adjustments. The
Organization should also continue educating personnel on the sliding fee discount
program and consider implementing internal audits of sliding fee discounts to
monitor and identify specific areas for further improvements or training.