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NACHC Comments on HRSA Sliding Fee Scale PIN

Published on Oct 3, 2012 by Sue Dormanen
On 9/28/12, NACHC submitted comments on HRSA's Draft PIN: Clarification of Sliding Fee Discount Program Requirements.

NACHC generally agrees with much of the Draft PIN, and appreciates clarification on the requirements that have resulted in some confusion among health centers, stakeholders and government representatives in recent years. Notwithstanding, the importance of maintaining flexibility based on a health center’s specific facts and circumstances should be explicitly recognized, writes NACHC.

Their general comments include:

• Request that HRSA include a statement under the “Applicability” section, declaring that in instances where detailed requirements are not provided within the PIN, health centers and their Boards of Directors maintain flexibility and discretion to develop, establish and implement standards, policies and procedures that are appropriate for the facts and circumstances of the particular health center and its patients.

• Request that HRSA clarify all statements throughout the Draft PIN regarding the Board’s role in approving policies and procedures to indicate that HRSA does not expect Boards to “overstep” into management’s role and exercise daily operational authorities including the establishment and implementation of procedures.

• Request that HRSA modify the Draft PIN to include a section on the application of fee and discount schedules to pharmacy and prescription drugs.

Read NACHC's full comments.

AND SEE: CPCA also has submitted comments, as reported in their Weekly Update of 10/3/12.


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