Community health center marketing: sliding fee notices, grant-funded ads and federal funding credits

A community health center markets for different reasons than a private practice. It may need to reach people who do not know they qualify for a discount, recruit clinicians for a hard-to-staff site, or tell a neighborhood that a new dental chair or behavioral health service is open. It also works under rules a private practice does not have: the Health Center Program statute, the HRSA compliance manual, and the federal cost principles that decide what an award can pay for.

This guide covers the parts of those rules that touch marketing: how to describe the sliding fee discount and the promise that no one is denied care for inability to pay, which advertising and public relations costs a federal award allows, how to acknowledge federal funding, and where offers to Medicare and Medicaid patients need a second look. HIPAA and language access rules apply to health centers too, and our other guides cover them, so this one links to those rather than repeating them. For outreach run with churches and neighborhood groups, see our guide to church and community partnerships. Certified rural health clinics follow a separate federal rule set; see rural health clinic marketing.

What is different about a health center

Health centers funded under section 330 of the Public Health Service Act, codified at 42 U.S.C. 254b, carry program requirements that shape what their marketing can say. The HRSA Health Center Program Compliance Manual sets out how HRSA expects those requirements to be met. Two chapters matter most for marketing: chapter 9 on the sliding fee discount program and chapter 16 on billing and collections.

The money behind the marketing also matters. Costs charged to a federal award are governed by the federal cost principles, which have their own section on advertising and public relations. A private practice can spend its own money on whatever lawful advertising it likes. A health center charging an ad to its award has to fit that ad into an allowed purpose.

Other rules are shared with private practices. A health center that is a HIPAA covered entity follows the same marketing and authorization rules, and patient stories need the same consent. Our guides to HIPAA marketing rules and patient testimonials and photos cover those.

Saying “no one is turned away” the way the rule says it

The core promise comes from the statute. Under 42 U.S.C. 254b(k)(3)(G)(iii), a health center must assure that no patient will be denied health care services due to an individual’s inability to pay, and that fees will be reduced or waived to make that possible. Chapter 16 of the compliance manual repeats the requirement and adds a distinction marketing copy should respect: a health center may, under a board-approved policy, limit or deny services to a patient who refuses to pay, as long as that policy separates refusal to pay from inability to pay and patients are told the amounts owed, the collection steps and how services will be limited.

So the accurate promise is about ability to pay, not about price. “Free care for everyone” is not what the rule says, and it is not how the sliding fee schedule works. Wording that stays close to the statute:

• “No one is denied care because they cannot pay.”
• “We offer discounts based on household income and family size.”
• “Ask our front desk how to apply for our sliding fee discount.”

Wording to avoid, because it promises more than the program does: “all care is free”, “no bills, ever”, or “everyone qualifies”. A patient whose income is above the discount range, or who owes a nominal charge, will read those lines as a broken promise.

Describing the sliding fee discount

Chapter 9 of the compliance manual describes the discount program in terms marketing can use directly. A health center must base sliding fee eligibility only on income and family size. The schedule gives a full discount at or below 100 percent of the current Federal Poverty Guidelines, partial discounts above 100 percent and up to 200 percent in at least three pay classes, and no discount above 200 percent. A health center may set a flat nominal charge for patients at or below 100 percent, but that charge must be nominal from the patient’s point of view and less than the fee in the first pay class above 100 percent. The regulation at 42 CFR 51c.303(f) states the same full-discount and no-discount limits.

Chapter 9 also lists informing patients as part of compliance. Among the examples it gives are materials in the languages and literacy levels of the patient population, information during intake, and information on the health center’s website. That makes a clear sliding fee page on the website part of running the program, not only marketing.

A useful sliding fee page answers these questions in plain words:

• Who can apply, stated as income and family size, with no other conditions the board policy does not include.
• Which services the discount applies to, and whether separate schedules exist for medical, dental or contracted services.
• What documents to bring, and what happens if a patient cannot provide them.
• Whether there is a nominal charge for patients at the lowest income level.
• Whether supplies such as eyeglasses, dentures or prescriptions are charged separately, which chapter 16 says patients must be told before the service.
• How often eligibility is reassessed, and who to call with questions.

If you publish the income table itself, update it when the schedule is updated. Chapter 9 expects the schedule to incorporate the most recent poverty guidelines, so a page showing last year’s figures is out of step with the program. Our guide to advertising cash prices covers how to keep published prices and their conditions honest.

Language access and accessibility

Chapter 9 names language and literacy level as part of informing patients about discounts. The federal language access and nondiscrimination rules under Section 1557, including the notice and tagline requirements, apply to health programs that receive federal financial assistance from HHS. Our guide to Spanish-language and multilingual marketing covers those requirements and translation quality, and our guide to website accessibility for medical practices covers the accessibility rules for websites and apps.

Paying for advertising with federal award funds

HHS adopted the government-wide cost principles in 2 CFR part 200 by a rule published at 89 FR 80055 on October 2, 2024 and effective October 1, 2025. Older award documents cite 45 CFR part 75. The advertising and public relations section is nearly identical in both, at 45 CFR 75.421 and 2 CFR 200.421, so the practical answer is the same. Check which one your notice of award cites.

Under that section, advertising costs are the costs of advertising media and related administrative costs, and the media named include newspapers, radio and television, direct mail, exhibits and electronic transmittals. The only allowable advertising costs are those solely for:

• recruiting personnel required to perform the federal award;
• procuring goods and services for the award;
• disposing of scrap or surplus materials acquired under the award, with a limited exception; or
• program outreach and other specific purposes necessary to meet the award’s requirements.

Public relations, which the rule defines to include community relations, is allowable only when the award requires it, when it communicates with the public and press about specific activities or accomplishments that result from the award, or when it is general liaison with news media limited to keeping the public informed on matters of public concern.

The same section lists costs that are unallowable. They include advertising and public relations designed solely to promote the organization, costs of promotional items and memorabilia, and costs of displays, exhibits, meeting rooms and staff time for events related to other activities of the organization.

In practice, that sorts health center marketing into three groups. An ad telling a neighborhood that the health center sees patients regardless of ability to pay, or that a new service in the approved scope is open, is the kind of program outreach the rule allows. A recruitment ad for a clinician the award needs fits the first purpose, and our guide to medical practice job ads covers the separate rules for that wording. Branded giveaways, image campaigns about the organization itself and booths at unrelated events belong outside the award, paid from other funds if at all. Our guide to health fairs and screening events covers the patient-facing side of events.

Keep records that show which allowed purpose each ad charged to the award served, so the cost can be supported if it is reviewed.

Acknowledging federal funding

HRSA’s page on acknowledging federal funding says that when a work product uses funds from HHS, the recipient must say so, and that Congress requires this through annual appropriations. The page lists four elements: who funded the product (HRSA and HHS), the award amount, the percentage of federal funding to total costs, and a disclaimer that the content is the recipient’s and is not endorsed by HRSA or HHS. It points to sample text in the HHS Grants Policy Statement that names a website among the products it covers.

HRSA’s frequently asked questions on the same page answer the points that come up with marketing materials. HRSA recommends using the annual award amount for the budget period, including supplements and carryover approved on the most recent notice of award. You do not have to calculate the exact cost of each document. Statements on products already posted do not have to be updated when a later notice of award changes the amount. The requirement continues after the period of performance ends. If you want wording other than the sample, HRSA says to consult your project officer.

For a website, that usually means one acknowledgment in a consistent place, such as the footer or an about page, rather than a statement on every post. Check with your project officer before you settle on placement.

Offers, waivers and Medicare or Medicaid patients

When a health center’s offers can reach Medicare or Medicaid patients, the beneficiary inducement rule applies as it does to any practice. 42 U.S.C. 1320a-7a(a)(5) allows civil monetary penalties against anyone who offers remuneration to a Medicare or state health care program beneficiary that they know or should know is likely to influence the choice of provider. The OIG Policy Statement of December 7, 2016 reads nominal value as no more than $15 per item or $75 a year per patient, with no cash or cash equivalents.

Copay waivers need particular care. Under 42 U.S.C. 1320a-7a(i)(6), the general exception for waiving coinsurance and deductibles applies only if the waiver is not offered as part of any advertisement or solicitation, is not routine, and follows a good faith finding of financial need or reasonable collection efforts. The same paragraph also excludes practices listed in 42 U.S.C. 1320a-7b(b)(3), which include a waiver of Medicare Part B coinsurance by a federally qualified health center for an individual who qualifies for subsidized services under the Public Health Service Act.

That second exception is narrower than a general “we waive copays” ad. It covers a specific waiver for specific patients. Describe the sliding fee discount as the program it is, and have counsel review any ad that mentions waiving copays or coinsurance before it runs. Our guide to marketing to Medicare patients covers the other exceptions and Medicare wording, and our guide to marketing to Medicaid patients covers Medicaid managed care plan rules and plan directories.

Patient messages and HIPAA

A health center sends reminders, outreach for screenings and enrollment help to its own patients. Under 45 CFR 164.501, communications about the covered entity’s own health-related services, and treatment communications, are excluded from the definition of marketing unless the covered entity receives financial remuneration from a third party for making them. Where a message is marketing, 45 CFR 164.508(a)(3) requires the patient’s written authorization. Our guides to HIPAA marketing rules and medical practice direct mail cover how to sort messages and mailings.

A free or charitable clinic that does not bill insurance works under a different federal definition, with its own volunteer liability program and donor rules. See our guide to free clinic marketing.

Illustration: one outreach campaign checked against the rules

Illustration: a health center opens a dental service within its approved scope and plans a campaign. The campaign has a bilingual web page about the new service, a short radio spot, a direct mail postcard to nearby households, and branded toothbrushes for a school event.

• The web page says the health center sees patients regardless of ability to pay, explains the sliding fee discount by income and family size, lists what to bring, and links to the full sliding fee page.
• The radio spot and postcard announce the new service and invite people to call. They describe a service in the approved scope, which fits program outreach, and the cost is recorded against that purpose.
• The toothbrushes are promotional items, which the cost principles list as unallowable, so they are paid from other funds or dropped.
• The postcard goes to a neighborhood list, not to patient records, so HIPAA marketing rules do not decide it, and nothing on it suggests a condition.
• The web page and postcard carry the federal funding acknowledgment in the form the project officer approved.

Checklist before a health center campaign goes out

• Does the copy describe ability to pay accurately, without promising free care for everyone?
• Is the sliding fee discount described by income and family size only, matching the board policy?
• Is the published income table current with the latest poverty guidelines?
• Are separate charges for supplies such as eyeglasses or dentures explained before the service?
• Are materials available in the languages and literacy levels of your patient population?
• If the ad is charged to the award, which allowed purpose does it serve, and is that recorded?
• Are promotional items and image-only campaigns kept off the award?
• Does the product carry the federal funding acknowledgment your project officer accepts?
• Does any offer reach Medicare or Medicaid patients, and has it been checked against 42 U.S.C. 1320a-7a(a)(5)?
• Does any ad mention waiving copays, and has counsel reviewed it?

How we help

We build websites, local search, Google Ads and AI front desk tools for independent practices and community providers. Our healthcare SEO work can help people searching nearby find a clear sliding fee page and the services you offer, and our medical website design work can give you a site that is readable in the languages your patients use. We do not decide which costs your award allows; your notice of award, your project officer and your counsel do. Our tools are built with HIPAA in mind. We confirm in writing what a BAA covers before any patient information flows through a tool, and if it is not covered, we do not route patient information through it.

Frequently asked questions

Sources

• 42 U.S.C. 254b: Health centers (subsection (k)(3)(G), fees, discounts and inability to pay)
• 42 CFR 51c.303: Other requirements (paragraphs (f) and (g), fee schedule and discounts)
• HRSA Health Center Program Compliance Manual, Chapter 9: Sliding Fee Discount Program
• HRSA Health Center Program Compliance Manual, Chapter 16: Billing and Collections
• 45 CFR 75.421: Advertising and public relations
• 2 CFR 200.421: Advertising and public relations
• 2 CFR 300.1: Adoption of 2 CFR part 200 by HHS
• 89 FR 80055: HHS adoption of the Uniform Administrative Requirements, Cost Principles, and Audit Requirements (October 2, 2024, effective October 1, 2025)
• HRSA: How to acknowledge federal funding (last reviewed September 2025)
• 42 U.S.C. 1320a-7a: Civil monetary penalties (subsections (a)(5) and (i)(6))
• 42 U.S.C. 1320a-7b: Criminal penalties for acts involving federal health care programs (subsection (b)(3)(D))
• OIG Policy Statement Regarding Gifts of Nominal Value to Medicare and Medicaid Beneficiaries (December 7, 2016)
• 45 CFR 164.501: Definitions (marketing)
• 45 CFR 164.508: Uses and disclosures for which an authorization is required

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