| Attachment IV - Summary of Comments Received on 0915-0327 |
| ISSUE |
Summary of Comments |
Actions to Address Comments |
| Shipping Address Clarifications |
Some covered entities disagree with the additional clarifying questions identifying wholly owned pharmacies and health care service delivery sites. |
HRSA developed the new shipping address submission process to streamline communication with covered entities and improve efficiency. The policy on what qualifies as a shipping address remains unchanged. |
| New documentation requirements for STD entities. |
Some covered entities are concerned that the proposed documentation to support STD eligibility will strain small and community-based STD clinics with limited administrative staff and funding. |
The new requirements for STD covered entities are intended to improve transparency, program integrity, and enable HRSA to more effectively confirm and maintain eligibility for all stakeholders. |
| Request for technical assistance to implement STD written agreements |
Some entities are concerned about the timeline and support needed to comply with the STD written agreements. Therefore, they request that technical assistance be provided by OPA and/or Apexus to help implement these new requirements and an implementation period to execute the changes. |
HRSA understands the operational challenges described in the comments and will take these concerns into account; however this documentation is necessary to provide oversight. HRSA will continue to provide outreach and technical assistance to ensure covered entities understand documentation requirements and can comply with them in a timely manner. |
| Trial Balance Language |
Some stakeholders are concerned with the language update regarding entities that should submit a trial balance that clearly indicates unique and separate reimbursable outpatient costs and charges for each service being requested. They are concerned this will create a burden or result in inappropriate modification or termination. |
HRSA is clarifying the required elements of a trial balance for hospitals registering a child site to ensure compliance with program requirements. The criteria for what qualifies as a child site remain unchanged. |