Audit 3036

Criteria or Specific Requirements Health centers must have a schedule of fees or payments for the provision of their health services consistent with locally prevailing rates or charges and designed to cover their reasonable costs of operation. They are also required to have a corresponding schedule of discounts applied and adjusted based on the patient’s ability to pay. The patient’s ability to pay is determined based on the official poverty guidelines, as revised annually by the U.S. Department of Health and Human Services (HHS). The poverty guidelines are issued each year in the Federal Register and HHS maintains a web page that provides the poverty guidelines. Non-grant funds (State, local, and other operational funding and fees, premiums, and third-party reimbursements which the project may reasonably be expected to receive, including any such funds in excess of those originally expected), shall be used as permitted under the law and may be used for such other purposes as are not specifically prohibited under the law if such use furthers the objectives of the project. Condition The Organization determines the amount of fees to be charged to a patient based on the patient’s income, expenses and number of dependents in conjunction with the sliding fee schedule. Of the 60 patients selected for testing, we noted 4 patients were charged the incorrect sliding fee amount, which resulted in the Organization undercharging 4 patients by a total of $60. Questioned Costs The total net amount undercharged was $60 for patients sampled. Cause and Effect The potential causes for the above errors are as follows:  Error by staff in determining the patient’s ability to pay; and  Lack of training. As a result, the determination of patient fee amounts charged may not be consistent with the sliding fee schedule. The errors for the 4 patients identified above occurred before management’s corrective action was implemented on April 30, 2023.Recommendation We recommend that the Organization’s controls and procedures be strengthened to ensure 1) income declaration is properly verified and adequately documented and 2) the sliding fee discount is properly determined and applied. The Organization should also provide additional training to staff involved in the sliding fee process and ensure that appropriate individuals are properly monitoring and reviewing the Organization’s compliance with program requirements. This will help ensure that the proper sliding fee is charged to patients and that program goals and objectives are being met. Views of Responsible Officials and Planned Corrective Actions The Organization will continue to implement the following measures to ensure compliance with the sliding fee discount program, and consistently assess patient income and family size. The Organization will continue to provide ongoing training to clinic staff who evaluate the sliding fee application at its clinic locations. The training consists of reviewing sliding fee program policies and procedures along with all applicable patient forms, sliding fee scale, and patient eligibility. The following quality control measures to ensure compliance have been implemented effective April 30, 2023; 1. Front Desk Peer Review of sliding fee application and verification of patient income and family size. 2. Enhance training materials to support Front Desk Staff with assessing sliding fee applications. 3. Quarterly feedback to Front Desk Staff based on sliding fee applications reviewed. Person Responsible: Kristopher D. Zuniga Position of Responsible Party: Chief Financial Officer Completion Date: April 30, 2023

Criteria or Specific Requirements Health centers must have a schedule of fees or payments for the provision of their health services consistent with locally prevailing rates or charges and designed to cover their reasonable costs of operation. They are also required to have a corresponding schedule of discounts applied and adjusted based on the patient’s ability to pay. The patient’s ability to pay is determined based on the official poverty guidelines, as revised annually by the U.S. Department of Health and Human Services (HHS). The poverty guidelines are issued each year in the Federal Register and HHS maintains a web page that provides the poverty guidelines. Non-grant funds (State, local, and other operational funding and fees, premiums, and third-party reimbursements which the project may reasonably be expected to receive, including any such funds in excess of those originally expected), shall be used as permitted under the law and may be used for such other purposes as are not specifically prohibited under the law if such use furthers the objectives of the project. Condition The Organization determines the amount of fees to be charged to a patient based on the patient’s income, expenses and number of dependents in conjunction with the sliding fee schedule. Of the 60 patients selected for testing, we noted 4 patients were charged the incorrect sliding fee amount, which resulted in the Organization undercharging 4 patients by a total of $60. Questioned Costs The total net amount undercharged was $60 for patients sampled. Cause and Effect The potential causes for the above errors are as follows:  Error by staff in determining the patient’s ability to pay; and  Lack of training. As a result, the determination of patient fee amounts charged may not be consistent with the sliding fee schedule. The errors for the 4 patients identified above occurred before management’s corrective action was implemented on April 30, 2023.Recommendation We recommend that the Organization’s controls and procedures be strengthened to ensure 1) income declaration is properly verified and adequately documented and 2) the sliding fee discount is properly determined and applied. The Organization should also provide additional training to staff involved in the sliding fee process and ensure that appropriate individuals are properly monitoring and reviewing the Organization’s compliance with program requirements. This will help ensure that the proper sliding fee is charged to patients and that program goals and objectives are being met. Views of Responsible Officials and Planned Corrective Actions The Organization will continue to implement the following measures to ensure compliance with the sliding fee discount program, and consistently assess patient income and family size. The Organization will continue to provide ongoing training to clinic staff who evaluate the sliding fee application at its clinic locations. The training consists of reviewing sliding fee program policies and procedures along with all applicable patient forms, sliding fee scale, and patient eligibility. The following quality control measures to ensure compliance have been implemented effective April 30, 2023; 1. Front Desk Peer Review of sliding fee application and verification of patient income and family size. 2. Enhance training materials to support Front Desk Staff with assessing sliding fee applications. 3. Quarterly feedback to Front Desk Staff based on sliding fee applications reviewed. Person Responsible: Kristopher D. Zuniga Position of Responsible Party: Chief Financial Officer Completion Date: April 30, 2023