Multiple Nominal Charges

In the December 2019, “HRSA-BPHC Consultant eNews”, HRSA provided guidance on using multiple nominal charges based on special population status/funding stream. The article stated that a common question was whether a health center could have different nominal charges for patients who are identified as being part of a “special population?” 

An example of this would be whether a health center could apply no nominal charge for its homeless patients but assess a $20 nominal charge to the general patient population for the same service. HRSA explained that “eligibility for sliding fee discounts, including any nominal charges, is to be based solely on income and family size, not on whether patients are identified as being part of a “special population” or any other demographic category.

If a health center chooses to assess a nominal charge for patients with incomes at or below 100% of FPG, or to not assess any nominal charge for services, then this charge, or lack thereof, would apply to all patients based on income and family size.”Health centers can have multiple nominal charges, but only under specific circumstances. A health center is not allowed to establish different nominal charges within the same Sliding Fee Discount Schedule (SFDS).

However, if a health center has multiple SFDSs, it can set a distinct nominal charge for each SFDS. Each SFDS must be based on either the type of service (e.g., medical vs. dental, etc.) or the method of service delivery (e.g., direct provision vs. contracted services) and must comply with Health Center Program requirements.

Key points regarding nominal charges include:

• Nominal charges must be flat amounts that are "nominal" from the patient's perspective and not reflective of the actual cost of the service.

• These charges must be applied uniformly to all patients within the respective SFDS based solely on income and family size.

• Health centers must evaluate the effectiveness of each SFDS in reducing financial barriers to care.

As long as all of these points are met, the health center may have multiple nominal charges.

Having trouble moving toward HRSA continuous compliance? Contact our expert team today. Our FQHC Mock Site Visits and web-based HRSA Continual Compliance tools will help save you time and money.  

Revised: March 6, 2025