6.3 Financial Management

Part I: Guidelines for Delegate Agency Program Management and Administration

Delegates must maintain a financial management system that meets Federal and State regulations and complies with Federal standards to safeguard the use of funds. Written fiscal policies and procedures must be in place within the delegate agency. Documentation and records of all income and expenditures must be maintained.

The financial management systems of the delegate agencies must meet the following standards:

  • Financial reporting must be accurate, current and ensure complete disclosure of the financial results of supported activities in accordance with contract requirements;
  • Accounting records must adequately identify the source and application of funds and contain information pertaining to grant awards, obligations, unobligated balances, assets, liabilities, expenditures and income;
  • Effective internal control and accountability must be maintained to safeguard all cash, property, inventory and other assets assuring that assets are used solely for authorized purposes; and
  • Actual expenditures must be compared with budgeted amounts.

Delegate agencies are required to submit an annual budget with their grant application. Budget revisions are required for the following conditions:

  • Changes in award are issued (contract amendments)
  • Changes in the budget initiated by the delegate

All financial records of expenditures, third party reimbursements, CVR billed procedures listings, and other program income, as well as inventory records of equipment purchased with project funds, must be kept for a minimum of three years, or as local legal counsel advises.

Delegate agencies are required to submit the following financial reports. Refer to Section 6.7 for detailed information on all reporting requirements.

  1. FPAR Revenue Report
  2. Financial Status Report

Tracking systems must be in place to monitor funds and ensure accurate reporting. Forms were developed to assist delegate agencies with tracking, including the Grant Monitoring and Cash Received Report forms.

Payments to the delegate agencies are based on a capped "fee for service" system and are limited to the lesser of the dollar amount of services documented or the actual costs reported on the Financial Status Report.

Delegate agencies must assure that an annual audit is conducted and complies with Federal OMB Circular A-133. Audits of delegate agencies must be conducted in accordance with provisions of 45 CFR Part 74, Subpart C, and 45 CFR Part 92, Subpart C, as applicable. External auditors meeting established criteria for qualifications and independence must conduct the audits, which are to be submitted annually to DHS.

6.3a Charges, Billing and Collections

Delegates are responsible for the development and implementation of written policies and procedures for charging, billing, and collecting funds for services that are in compliance with Federal and State guidelines. Clients must not be denied family planning services or be subjected to any variation in quality of services because of inability to pay. Billing and collection procedures must include:

  1. Charges are based on a cost analysis of all family planning services provided by the delegate agency.
  2. A schedule of discounts and sliding fee schedule must be developed and implemented with sufficient proportional increments so that inability to pay is never a barrier to service. A schedule of discounts is required for individuals with family incomes between 0 (zero)% and 250% of the federal poverty level. Fees may be waived for individuals who, as determined by the service site project director, are unable, for good cause, to pay for family planning services. The determination of fees and notice of any applicable waiver should be made prior to the delivery of services. (Refer to Appendix A for additional information on the development of a schedule of discounts and fee schedules).
  3. Clients with income below 100% of poverty are not assessed a fee. Fee schedules must include a zero fee category.
  4. Individual eligibility must be documented in the client chart. Income verification may be requested but cannot be required. Language used to request income verification must not establish barriers to care. Income must be reassessed with annual July 1st revised poverty guidelines or more frequently if indicated.
  5. Third party payers must be billed using total charges without applying any discount. Total charges represent the maximum fee ("customary and reasonable") on the sliding fee scale.
  6. Where reimbursement is available from Title XIX or Title XX of the Social Security Act, delegate agencies must have either a written agreement with the Title XIX or Title XX State agency or have evidence of the authority to bill the state agency through an approved provider/billing number.
  7. Bills (receipts) to clients must show total charges less any allowable discount. All clients must receive a receipt at the time of service.
  8. Eligibility for discounts for minors who request confidential services must be based on the income of the minor. Income actually available to the minor, such as wages from part-time employment or stipends paid directly to the minor, should be considered in determining the minor's ability to pay for services. Those services normally provided by parents/guardians, e.g., food, shelter, transportation, tuition, etc., should not be used in determining the minor's income. It is not allowable to have a general policy of flat fees for minors or a fee schedule that is different for minors than for other clients.
    When considering charges to minors for services, several conditions must be taken into account:
    1. If the minor is not emancipated and confidentiality is not a concern, the family's income must be considered in determining the charge.
    2. If the minor has not requested confidentiality but the parent refuses financial support, charges must be based on the minor's income.
    3. If the minor requests confidential services, without the involvement of a principal family member, charges must be based on the minor's income.
    4. If the minor is in the situation where confidentiality is restricted to one family member (e.g., one parent is aware of the minor seeking services, but the other is not, because of a disagreement regarding the minor's right to receive family planning services), the charges shall be based on the minor's income if the minor's confidentiality would be breached.
    5. If the minor presents evidence of parent's insurance, but requests confidential services, charges must be based on the minor's income. (An insurance company may submit Explanation of Benefits to the minor's parent and thereby breach confidentiality).
  9. Reasonable effort to collect charges without jeopardizing client confidentiality must be made. Example: Collection agencies cannot be used for clients requesting confidential services.
  10. A method for aging of outstanding accounts must be in place.
  11. Voluntary donations from clients are permissible, however:
    • Clients must not be pressured to make donations;
    • A specific amount must not be suggested;
    • Donations must not be a prerequisite to the provision of services or supplies; and
    • Donations cannot establish an "amount due" on the client's account.
    • Donations from clients do not waive the billing requirements set above.
  12. Client income must be re-evaluated annually. Reassessment should occur at a minimum during the client's first visit after July 1 to correlate with Federal Poverty Level changes, and periodically as needed. When client income changes, eligibility documentation must be complete and consistent across records.

Delegate agencies are allowed to revise their sliding fee schedules, under certain circumstances, such as to adjust for a cost increase in contraceptive methods or laboratory services, or for the addition of new services. If revisions are made to fee schedules, a revised budget must be submitted and approved by the Program.

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