Finding 2023-002 – Special Tests and Provisions – Sliding Fee (significant deficiency and
noncompliance)
Information on the federal program: U.S. Department of Health and Human Services, CFDA No.
93.224 and 93.527 Health Center Program Cluster
Criteria: 42 CFR Section 51c.303(d) defines required project elements to include developing a sound
control system to ensure compliance with the regulations and terms and conditions of the grant. 42
CFR Section 51c.303(f) establishes the requirement to have a schedule of fees or payments for the
provision of its services designed to cover its reasonable costs of operation and a corresponding
schedule of discounts adjusted on the basis of the patient's ability to pay. Such schedule of discounts
shall provide for a full discount to individuals and families with annual incomes at or below those set
forth in the most recent CSA Poverty Income Guidelines and for no discount to individuals and families
with annual incomes greater than twice those set forth in such guidelines, except that nominal fees
for services may be collected from individuals with annual incomes at or below such levels where
imposition of such fees is consistent with project goals.
Condition: We tested the controls over the application of the sliding scale fee discount for 40 patient
visits during the year. Out of the 40 tested, we noted 11 patients with one or more exceptions. We
noted 11 instances in which the sliding fee discount was not properly applied and 11 instances in
which the income documentation was not provided by the patient to determine the discount. In
addition, we noted that documentation of review of the patient files was not properly documented.
Cause: Eligibility documentation obtained by the Organization for each patient is accumulated using
an intake form and income verification source documents. Per the Organization, the control system
over the sliding fee program includes periodic review of patient files for accuracy and completeness.
These file reviews were not properly documented and therefore could not be verified as performed.
For the exceptions noted by testing compliance, the income source documentation was not provided
by the patient to support the amounts on file and these patients were given the 100% discount.
Effect: Sliding fee discounts were not appropriately applied and patients were charged the incorrect
amounts.
Recommendation: We recommend the Organization strengthen its policies and procedures
surrounding the sliding fee scale to ensure compliance with the special tests and provision
requirements.
Views of Responsible Officials and Planned Corrective Action: See Management’s View and
Corrective Action Plan included at the end of the report.
Finding 2023-002 – Special Tests and Provisions – Sliding Fee (significant deficiency and
noncompliance)
Information on the federal program: U.S. Department of Health and Human Services, CFDA No.
93.224 and 93.527 Health Center Program Cluster
Criteria: 42 CFR Section 51c.303(d) defines required project elements to include developing a sound
control system to ensure compliance with the regulations and terms and conditions of the grant. 42
CFR Section 51c.303(f) establishes the requirement to have a schedule of fees or payments for the
provision of its services designed to cover its reasonable costs of operation and a corresponding
schedule of discounts adjusted on the basis of the patient's ability to pay. Such schedule of discounts
shall provide for a full discount to individuals and families with annual incomes at or below those set
forth in the most recent CSA Poverty Income Guidelines and for no discount to individuals and families
with annual incomes greater than twice those set forth in such guidelines, except that nominal fees
for services may be collected from individuals with annual incomes at or below such levels where
imposition of such fees is consistent with project goals.
Condition: We tested the controls over the application of the sliding scale fee discount for 40 patient
visits during the year. Out of the 40 tested, we noted 11 patients with one or more exceptions. We
noted 11 instances in which the sliding fee discount was not properly applied and 11 instances in
which the income documentation was not provided by the patient to determine the discount. In
addition, we noted that documentation of review of the patient files was not properly documented.
Cause: Eligibility documentation obtained by the Organization for each patient is accumulated using
an intake form and income verification source documents. Per the Organization, the control system
over the sliding fee program includes periodic review of patient files for accuracy and completeness.
These file reviews were not properly documented and therefore could not be verified as performed.
For the exceptions noted by testing compliance, the income source documentation was not provided
by the patient to support the amounts on file and these patients were given the 100% discount.
Effect: Sliding fee discounts were not appropriately applied and patients were charged the incorrect
amounts.
Recommendation: We recommend the Organization strengthen its policies and procedures
surrounding the sliding fee scale to ensure compliance with the special tests and provision
requirements.
Views of Responsible Officials and Planned Corrective Action: See Management’s View and
Corrective Action Plan included at the end of the report.
Finding 2023-002 – Special Tests and Provisions – Sliding Fee (significant deficiency and
noncompliance)
Information on the federal program: U.S. Department of Health and Human Services, CFDA No.
93.224 and 93.527 Health Center Program Cluster
Criteria: 42 CFR Section 51c.303(d) defines required project elements to include developing a sound
control system to ensure compliance with the regulations and terms and conditions of the grant. 42
CFR Section 51c.303(f) establishes the requirement to have a schedule of fees or payments for the
provision of its services designed to cover its reasonable costs of operation and a corresponding
schedule of discounts adjusted on the basis of the patient's ability to pay. Such schedule of discounts
shall provide for a full discount to individuals and families with annual incomes at or below those set
forth in the most recent CSA Poverty Income Guidelines and for no discount to individuals and families
with annual incomes greater than twice those set forth in such guidelines, except that nominal fees
for services may be collected from individuals with annual incomes at or below such levels where
imposition of such fees is consistent with project goals.
Condition: We tested the controls over the application of the sliding scale fee discount for 40 patient
visits during the year. Out of the 40 tested, we noted 11 patients with one or more exceptions. We
noted 11 instances in which the sliding fee discount was not properly applied and 11 instances in
which the income documentation was not provided by the patient to determine the discount. In
addition, we noted that documentation of review of the patient files was not properly documented.
Cause: Eligibility documentation obtained by the Organization for each patient is accumulated using
an intake form and income verification source documents. Per the Organization, the control system
over the sliding fee program includes periodic review of patient files for accuracy and completeness.
These file reviews were not properly documented and therefore could not be verified as performed.
For the exceptions noted by testing compliance, the income source documentation was not provided
by the patient to support the amounts on file and these patients were given the 100% discount.
Effect: Sliding fee discounts were not appropriately applied and patients were charged the incorrect
amounts.
Recommendation: We recommend the Organization strengthen its policies and procedures
surrounding the sliding fee scale to ensure compliance with the special tests and provision
requirements.
Views of Responsible Officials and Planned Corrective Action: See Management’s View and
Corrective Action Plan included at the end of the report.
Finding 2023-002 – Special Tests and Provisions – Sliding Fee (significant deficiency and
noncompliance)
Information on the federal program: U.S. Department of Health and Human Services, CFDA No.
93.224 and 93.527 Health Center Program Cluster
Criteria: 42 CFR Section 51c.303(d) defines required project elements to include developing a sound
control system to ensure compliance with the regulations and terms and conditions of the grant. 42
CFR Section 51c.303(f) establishes the requirement to have a schedule of fees or payments for the
provision of its services designed to cover its reasonable costs of operation and a corresponding
schedule of discounts adjusted on the basis of the patient's ability to pay. Such schedule of discounts
shall provide for a full discount to individuals and families with annual incomes at or below those set
forth in the most recent CSA Poverty Income Guidelines and for no discount to individuals and families
with annual incomes greater than twice those set forth in such guidelines, except that nominal fees
for services may be collected from individuals with annual incomes at or below such levels where
imposition of such fees is consistent with project goals.
Condition: We tested the controls over the application of the sliding scale fee discount for 40 patient
visits during the year. Out of the 40 tested, we noted 11 patients with one or more exceptions. We
noted 11 instances in which the sliding fee discount was not properly applied and 11 instances in
which the income documentation was not provided by the patient to determine the discount. In
addition, we noted that documentation of review of the patient files was not properly documented.
Cause: Eligibility documentation obtained by the Organization for each patient is accumulated using
an intake form and income verification source documents. Per the Organization, the control system
over the sliding fee program includes periodic review of patient files for accuracy and completeness.
These file reviews were not properly documented and therefore could not be verified as performed.
For the exceptions noted by testing compliance, the income source documentation was not provided
by the patient to support the amounts on file and these patients were given the 100% discount.
Effect: Sliding fee discounts were not appropriately applied and patients were charged the incorrect
amounts.
Recommendation: We recommend the Organization strengthen its policies and procedures
surrounding the sliding fee scale to ensure compliance with the special tests and provision
requirements.
Views of Responsible Officials and Planned Corrective Action: See Management’s View and
Corrective Action Plan included at the end of the report.
Finding 2023-002 – Special Tests and Provisions – Sliding Fee (significant deficiency and
noncompliance)
Information on the federal program: U.S. Department of Health and Human Services, CFDA No.
93.224 and 93.527 Health Center Program Cluster
Criteria: 42 CFR Section 51c.303(d) defines required project elements to include developing a sound
control system to ensure compliance with the regulations and terms and conditions of the grant. 42
CFR Section 51c.303(f) establishes the requirement to have a schedule of fees or payments for the
provision of its services designed to cover its reasonable costs of operation and a corresponding
schedule of discounts adjusted on the basis of the patient's ability to pay. Such schedule of discounts
shall provide for a full discount to individuals and families with annual incomes at or below those set
forth in the most recent CSA Poverty Income Guidelines and for no discount to individuals and families
with annual incomes greater than twice those set forth in such guidelines, except that nominal fees
for services may be collected from individuals with annual incomes at or below such levels where
imposition of such fees is consistent with project goals.
Condition: We tested the controls over the application of the sliding scale fee discount for 40 patient
visits during the year. Out of the 40 tested, we noted 11 patients with one or more exceptions. We
noted 11 instances in which the sliding fee discount was not properly applied and 11 instances in
which the income documentation was not provided by the patient to determine the discount. In
addition, we noted that documentation of review of the patient files was not properly documented.
Cause: Eligibility documentation obtained by the Organization for each patient is accumulated using
an intake form and income verification source documents. Per the Organization, the control system
over the sliding fee program includes periodic review of patient files for accuracy and completeness.
These file reviews were not properly documented and therefore could not be verified as performed.
For the exceptions noted by testing compliance, the income source documentation was not provided
by the patient to support the amounts on file and these patients were given the 100% discount.
Effect: Sliding fee discounts were not appropriately applied and patients were charged the incorrect
amounts.
Recommendation: We recommend the Organization strengthen its policies and procedures
surrounding the sliding fee scale to ensure compliance with the special tests and provision
requirements.
Views of Responsible Officials and Planned Corrective Action: See Management’s View and
Corrective Action Plan included at the end of the report.
Finding 2023-002 – Special Tests and Provisions – Sliding Fee (significant deficiency and
noncompliance)
Information on the federal program: U.S. Department of Health and Human Services, CFDA No.
93.224 and 93.527 Health Center Program Cluster
Criteria: 42 CFR Section 51c.303(d) defines required project elements to include developing a sound
control system to ensure compliance with the regulations and terms and conditions of the grant. 42
CFR Section 51c.303(f) establishes the requirement to have a schedule of fees or payments for the
provision of its services designed to cover its reasonable costs of operation and a corresponding
schedule of discounts adjusted on the basis of the patient's ability to pay. Such schedule of discounts
shall provide for a full discount to individuals and families with annual incomes at or below those set
forth in the most recent CSA Poverty Income Guidelines and for no discount to individuals and families
with annual incomes greater than twice those set forth in such guidelines, except that nominal fees
for services may be collected from individuals with annual incomes at or below such levels where
imposition of such fees is consistent with project goals.
Condition: We tested the controls over the application of the sliding scale fee discount for 40 patient
visits during the year. Out of the 40 tested, we noted 11 patients with one or more exceptions. We
noted 11 instances in which the sliding fee discount was not properly applied and 11 instances in
which the income documentation was not provided by the patient to determine the discount. In
addition, we noted that documentation of review of the patient files was not properly documented.
Cause: Eligibility documentation obtained by the Organization for each patient is accumulated using
an intake form and income verification source documents. Per the Organization, the control system
over the sliding fee program includes periodic review of patient files for accuracy and completeness.
These file reviews were not properly documented and therefore could not be verified as performed.
For the exceptions noted by testing compliance, the income source documentation was not provided
by the patient to support the amounts on file and these patients were given the 100% discount.
Effect: Sliding fee discounts were not appropriately applied and patients were charged the incorrect
amounts.
Recommendation: We recommend the Organization strengthen its policies and procedures
surrounding the sliding fee scale to ensure compliance with the special tests and provision
requirements.
Views of Responsible Officials and Planned Corrective Action: See Management’s View and
Corrective Action Plan included at the end of the report.