Title X Guidelines Revision: Program Requirements

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Title X Guidelines Revision: Program Requirements PROGRAM REQUIREMENTS O V E R V I E W CDR Nancy Mautone-Smith, MSW, LCSW Public Health Advisor Office of Population Affairs

Title X Program Requirements 17 Title X Legislation: Statute (Sec. 1001, 1003, 1004, 1005, 1006, 1007, 1008) Title X Regulations (42CFR59 Subpart A, Subpart C, 42CFR50 Subpart B) Legislative Mandates (Appropriations Language) Program Instructions Other Program Requirements and Priorities

Title X Program Requirements Document provides a central place for grantees to reference applicable regulations Organized in user-friendly format Requirements are referenced back to statute or regulation 15 sections address a variety of elements required for Title X funded family planning services projects

Title X Program Requirements: 15 Sections 1. Applicability 2. Definitions 3. Eligibility 4. Application 5. Criteria for Funding 6. Notice of Award 7. Use of Grant Funds 8. Project Management and Administration 9. Project Services and Clients 10. Confidentiality 11. Community Participation, Education, and Project Promotion 12. Information and Education Materials Approval 13. Additional Administrative Requirements 14. Additional Conditions 15. Other Applicable HHS Regulations and Statutes

Sections 1-7 Grant application, award processes, grant administration Sections 8-12 Project Management, required services, confidentiality, community participation and I&E (Primarily addressed in Sections 3.0-4.0 of the 2001 Guidelines) (Primarily addressed in sections 6.0-7.0 of the 2001 Guidelines)

Sections 13-15 Additional Administrative Requirements, Additional Conditions, Other Applicable HHS Regulations and Statutes

Title X Program Requirements

Section 8: Project Management and Administration Key areas including: Voluntary Participation Prohibition of Abortion Structure and Management Charges, Billing and Collections Project Personnel Staff Training and Project Technical Assistance Planning and Evaluation

Section 9: Project Services and Clients Priority to low-income families Voluntary participation Clinical protocols- must be in accordance with Nationally recognized practice standards Services to be provided without regard to religion, race, color, national origin, disability, age, sex, number of pregnancies, or marital status Provision of social services related to family planning and referrals to and from other social and medical services agencies and ancillary services which may be necessary to facilitate clinic attendance

Section 9: Project Services and Clients Providing for coordination and use of referral arrangements with other providers of health care services, local health and welfare departments, hospitals, voluntary agencies, and health services projects supported by other federal programs All projects must provide for medical services related to family planning and the effective usage of contraceptive devices and practices, including the broad range of methods Pregnancy counseling requirements Adherence to longstanding mandates set out in the Appropriations Act (family participation, coercion counseling, and mandatory reporting)

Section 10: Confidentiality Every project must have safeguards to ensure client confidentiality Information may not be disclosed without the individual's documented consent, except as required by law or as may be necessary to provide services to the individual, with appropriate safeguards for confidentiality Information may otherwise be disclosed only in summary, statistical, or other form that does not identify the individual

Section 11: Community Participation, Education, and Project Promotion Participation by persons broadly representative of all significant elements of the population to be served and knowledgeable about the community s needs for family planning services Projects musts establish and implement planned activities to facilitate community awareness of and access to family planning services Must provide for community education programs (based on an assessment of the needs of the community) Should enhance community understanding of the objectives of the project, make known availability of services

Section 12-Information and Education Materials Approval Addresses Advisory Committee 5-9 members broadly representative of the community Committee must consider the educational and cultural backgrounds of the individuals to whom the materials are addressed They must consider the standards of the population or community to be served Review to ensure factually correct Determine if the material is suitable for the population or community to which it is to be made available Establish a written record of its determinations

2001 Program Guidelines A schedule of discounts must be developed 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 101% and 250% of the Federal poverty level

Example- What the Program Requirements Say: Section 8.5- Charges Billing, and Collections (excerpt) A schedule of discounts, based on ability to pay, is required for individuals with family incomes between 101% and 250% of the FPL (42 CFR 59.5(a)(8)) For persons from families whose income exceeds 250% of the FPL, charges must be made in accordance with a schedule of fees designed to recover the reasonable cost of providing services (42 CFR 59.5 (a)(8))

What the Program Requirements DON T Say: Section 8.5- Charges Billing, and Collections Cost Analysis Sufficient Proportional Increments Individual Eligibility for a discount must be documented in the client s financial record At the time of services, clients who are responsible for paying any fee for their services must be given bills directly Bills to clients must show total charges less any allowable discounts

Summary: Title X Program Requirements Not NEW Document provides a more user-friendly source for Title X program statute and regulations Useful for administrators, prospective applicants, federal staff, etc. Less likely to change or need updating

QUESTIONS??