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Attachment 13: Health Center Program Compliance Narrative Instructions

You must upload a narrative as Attachment 13. Include the required sections to show you comply with program requirements in the Health Center Program Compliance Manual.

Refer to Appendix A: Health Center Program Compliance in the NOFO for further guidance.

Note: Attachment 13 will not count against the page limit.

Sliding fee discount program

(Include a narrative and refer to Attachment 10: Sliding Fee Discount Schedule and Form 5A: Services Provided)

Use this section to describe your sliding fee discount program (SFDP).

You must address each of the following elements of the program:

  • Applies consistently to all patients
  • Defines income and family
  • Aligns with the current Federal Poverty Guidelines (FPG)
  • Includes methods for assessing all patients for sliding fee discount eligibility based only on income and family size
  • Ensures that you adjust patient charges based on ability to pay and consistent with the Sliding Fee Discount Schedule (SFDS)
  • Have policies related to nominal charges for patients with incomes at or below 100% of the current FPG

    Describe whether the nominal charge is one of the following:

    • Flat
    • Set at a level that is nominal from the perspective of the patient
    • Does not reflect the actual cost of the service being provided

Or,

State if you do not have a nominal charge for patients with incomes at or below 100% of the FPG.

Your current SFDS – that you uploaded in Attachment 10: Sliding Fee Discount Schedule -- should support your description. The schedule should include all services that you provide directly. This should be consistent with Form 5A: Services Provided (PDF - 131 KB), Column 1. If you have more than one SFDS, upload all of them in Attachment 10.

The SFDS should describe discounts as follows:

  • Provide a full discount for individuals and families with annual incomes at or below 100% of the current FPG, unless a health center elects to have a nominal charge, which would be less than the fee or discount paid by a patient in the first sliding fee discount pay class above 100% of the FPG.
  • Provide partial discounts for individuals and families with incomes above 100% of the current FPG and at or below 200% of the current FPG, and those discounts adjust based on gradations in income levels and include at least three discount pay classes.
  • Provide no discounts to individuals and families with annual incomes above 200% of the current FPG.

Contracts and sub-awards

(Include a narrative and refer to Attachment 7: Summary of Contracts and Agreements and Form 8: Health Center Agreements)

Use this section to describe your oversight of all contracts and sub-awards to show that:

  • All Health Center Program requirements apply to all subrecipients.
  • Any distinct statutory, regulatory, and policy requirements of other federal programs associated with their HRSA-approved scope of project apply to all subrecipients.
  • All costs paid for by the federal subaward are allowable consistent with Federal Cost Principles.

In addition, you must use Attachment 7: Summary of Contracts and Agreements and Form 8: Health Center Agreements (PDF - 193 KB) to show that all contracts and sub-awards include:

  • Specific activities or services the health center will perform or goods it will provide
  • Mechanisms for the health center to monitor how the contractor performs
  • Requirements for the contractor to provide the necessary data which meets the recipient’s applicable federal financial and programmatic reporting requirements, as well as provisions addressing record retention and access, audit, and property management.

Billing and collections

(Include a narrative and refer to Form 3: Income Analysis)

Use this section to describe how you conduct billing and collections, including:

  • Your participation in Medicare, Medicaid, Children’s Health Insurance Program (CHIP) and as appropriate, other public or private assistance programs or health insurance. This description should be consistent with Form 3: Income Analysis (PDF - 229 KB).
  • Your board-approved policies and your procedures for waiving or reducing fees to ensure that health centers will waive or reduce fees or payments based on specific circumstances due to any patient’s inability to pay.

Governance: board authority

(Include a narrative and refer to Attachment 2: Bylaws, Attachment 3: Project Organizational Chart, Attachment 6: Co-Applicant Agreement (if applicable), Attachment 8: Articles of Incorporation, and Form 8: Health Center Agreements)

Use this section to describe where you document the following board authority requirements in Attachment 2: Bylaws and, if it applies, Attachment 8: Articles of Incorporation (new applicants only) and Attachment 6: Co-Applicant Agreement:

  • Holding monthly meetings.
  • Approving the selection (and dismissal or termination, as appropriate) of the PD/CEO.
  • Approving the annual Health Center Program project budget and applications.
  • Approving proposed health center services and the locations and hours of operation of health center sites.
  • Evaluating the performance of the health center.
  • Establishing or adopting policies related to the operations of the health center.
  • Ensuring the health center complies with applicable federal, state, and local laws and regulations.

Also, describe how your governing board maintains the authority for oversight of the proposed Health Center Program project.

Refer to specific sections in Attachment 2: Bylaws, Attachment 6: Co-Applicant Agreement, Attachment 8: Articles of Incorporation (new applicants only), and Form 8: Health Center Agreements (PDF - 193 KB)

Specifically, address the following:

  • No other individual, entity, or committee (including, but not limited to, an executive committee the board authorizes, and consistent with Attachment 3: Project Organizational Chart) reserves approval authority or has veto power over the board regarding the required authorities and functions.
  • In cases where you collaborate with other entities in fulfilling the health center’s proposed scope of project, such collaboration or agreements with other entities do not restrict or infringe upon the board’s required authorities and functions.
  • Public agency applicants with co-applicant board: co-applicant agreement delegates the required authorities and functions to the co-applicant board and delineates the roles and responsibilities of the public agency and the co-applicant in carrying out the project (consistent with Attachment 6: Co-Applicant Agreement).

Governance: board composition

(Include a narrative and refer to Attachment 2: Bylaws)

Use this section to describe where in Attachment 2: Bylaws and, if applicable, Attachment 6: Co-Applicant Agreement, you document the following board composition requirements:

  • Board size is at least 9 and no more than 25 members, with either a prescribed number or range of board members.
  • At least 51% of board members are patients the health center serves.
  • Patient members of the board, as a group, represent the people the health center serves in terms of demographic factors (for example, gender, race, ethnicity).
  • Non-patient members represent the community that the health center or the health center’s service area serves.
  • Select non-patient members so they can provide relevant expertise and skills (for example, community affairs, local government, finance and banking, legal affairs, trade unions and other commercial and industrial concerns, social services).
  • No more than one-half of non-patient board members may earn more than 10% of their annual income from the health care industry.
  • Health center employees and immediate family members (that is, spouses, children, parents, or siblings through blood, adoption, or marriage) of employees may not be health center board members.
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