Imposition of Charges: Not Just an Imposition, It’s the Law!

• Imposition of Charges: all activities, policies, and procedures related to assessing RWHAP patient charges as outlined in legislation.
• Fee Schedule: a complete listing of billable services and their associated fees based on locally prevailing rates or charges. A fee schedule is not a schedule of charges. A fee schedule is not required by RWHAP legislation, but having one in place is considered a best practice and, for those multi-funded clinics, is a requirement for HRSA’s Bureau of Primary Health Care (BPHC) grant recipients.
• Schedule of Charges: fees imposed on RWHAP patient for services based on the patient’s annual gross income. A schedule of charges may take the form of a flat rate or a varying rate (e.g., sliding fee scale).
• Nominal Charge: a fee greater than zero.
• Cap on Charges: the limitation on aggregate charges imposed during the calendar year based on a patient’s annual gross income. All fees must be waived once a patient reaches their cap for that calendar year.
• Federal Poverty Level (FPL): a measure of income issued every year by the U.S. Department of Health and Human Services (HHS). Federal poverty levels are commonly used to determine eligibility for certain programs and benefits such as Medicaid, Supplemental Nutrition Assistance Program (SNAP), and the Children’s Health Insurance Program (CHIP)
• Annual Gross Income: a measure of income. There are three ways to measure an individual’s Annual Gross Income, and any of these forms of income could be used by the provider for the purposes of imposition of charges.*
• Gross Income, which is the total amount of income earned from all sources during the calendar year before taxes;
• Adjusted Gross Income, which is gross income less deductions; and
• Modified Adjusted Gross Income (MAGI), which is Adjusted Gross Income plus certain deductions.

Notes

* Although many RWHAP providers opt to use MAGI since that is measure used to make Medicaid and CHIP eligibility determinations, providers should keep in mind that MAGI may not provide a patient’s most current income status which is important when determining imposition of charges.