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Imposition of Charges: Glossary of Terms and Webinar

January 30, 2019

HRSA HIV/AIDS Bureau (HAB)

​The Imposition of Charges requirement is a term used to describe all activities, policies, and procedures related to assessing RWHAP patient charges as outlined in legislation. The HRSA RWHAP statute defines who MUST NOT have a charge imposed, who MUST have a charge imposed, and limits the amount that CAN be imposed in a calendar year.

Glossary

See below for related webinar.

Annual Gross Income 

A measure of income. There are several ways to measure an individual’s Annual Gross Income. For example, these forms of income could be used by the provider for the purposes of imposition of charges: 

  • Gross Income: the total amount of income earned from all sources during the calendar year before taxes 
  • Adjusted Gross Income: gross income less deductions 

Cap on Charges

The limitation on aggregate charges imposed during the calendar year based on patient’s annual gross income. All fees must be waived once a RWHAP patient reaches their cap for that calendar year. 

Documentation

Papers and documents documents required from clients, as defined by the recipient, in order to assure all RWHAP statutory requirements are met. 

Federal Poverty Level (FPL)

A measure of income issued every year by HHS. Federal poverty levels are commonly used to determine eligibility for certain programs and benefits such as Medicaid, Food Stamps, the Children’s Health Insurance Program (CHIP), and RWHAP. 

Fee Schedule

complete listing of billable services, those with UCR fees, and their associated fees based on locally prevailing rates or charges. A fee schedule is used by healthcare providers to identify which services they bill for and for how much. A fee schedule is not a schedule of charges. A fee schedule is not required by the RWHAP legislation, but it may be useful as the basis for a schedule of charges. Having one in place is considered a best practice and, for those multi-funded clinics, is a requirement for HRSA Bureau of Primary Health Care (BPHC) grant recipients. 

HIV-related Charges

Those charges a RWHAP recipient imposes on the patient plus any other out of-pocket charges related to their HIV care (as determined by their provider) that a patient incurs and reports to their RWHAP recipient/provider. These charges can be from any provider as long as the service is a RWHAP allowable service. 

Imposition of Charges

All activities, policies, and procedures related to assessing RWHAP patient charges as outlined in legislation. Applicable Services: any RWHAP service with a distinct fee typically charged in the local market. In the broader healthcare community this distinct fee is often referred to as a usual, customary, and reasonable (UCR) fee.

Schedule of Charges

Fees imposed on the 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). The schedule of charges is how you know what amount of money to charge a patient. The schedule of charges applies to uninsured patients with incomes above 100% FPL, and may be applied to insured patients as determined by RWHAP recipients’ policies and procedures. When applied to insured patients, recipients should consider how their policy will be applied uniformly to all insured patients, rather than on a case-by-case basis.

Nominal Charge

A fee greater than zero.

UCR

Usual, customary, and reasonable, as in services for which there is a usual, customary, and reasonable fee associated. Such services are found on a fee schedule. 

Waiver

A waiver of the imposition of charges requirement can only be requested by RWHAP recipients operating as free clinics (e.g. healthcare for the homeless clinics). Only a handful of RWHAP recipients are operating as free clinics; therefore, other RWHAP recipients/subrecipients should be charging patients over 100% FPL for applicable services – even if it is only $1. Organizations that receive funding from RWHAP and other Federal funding sources (i.e., facilities operated directly by the Indian Health Service or by Tribes through a contract with the Indian Health Service, Community Health Centers) must follow the requirements imposed by each Federal program. To the extent that services under the RWHAP are provided and attributed to the RWHAP, RWHAP statutory requirements on imposition of charges must be followed.

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