Audit 323284

Finding No.2023-001: Inaccurate Application of Sliding fee Discounts (Significant Deficiency) Assistance Listing Number: 93.829 Assistance Listing Program Title: Section 223 Demonstration Programs to Improve Community Mental Health Services. Federal Agency: Department of Health and Human Services (HHS) - Substance Abuse and Mental Health Services Administration (SAMHSA) Passed Through Entity: Not applicable Federal Award Number: 1H79SM085136-01 Federal Award Year: August 31, 2021 – August 30, 2023 Compliance Requirement: Special Tests and Provisions – Sliding Fee Discounts 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, expense, and number of dependents in conjunction with the sliding fee schedule. Of the 25 patients selected for testing, we noted the following: - 4 patients were charged the incorrect sliding fee amount, which resulted in the Organization overcharging 2 patients by $10 each, while 2 patients were undercharged by $5 each. - 4 patients had no proof of income declaration and sliding fee application form on file. Due to an unsupported sliding fee discount, we were unable to determine if these 4 patients were eligible for the sliding fee and should have been charged the full amount totaling $523.48. Questioned Costs $513.48 in net undercharges for sliding fee patients sampled. Causes and Effect The potential cause for the above errors is as follows: - Error by staff in determining the patient’s ability to pay. - Lack of review and retention of sliding fee applications and income declaration forms. - Patients did not complete the required form necessary to determine the patient’s ability to pay. As a result, the determination of patient fees is not consistent with the sliding fee schedule. 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.

Finding No.2023-001: Inaccurate Application of Sliding fee Discounts (Significant Deficiency) Assistance Listing Number: 93.829 Assistance Listing Program Title: Section 223 Demonstration Programs to Improve Community Mental Health Services. Federal Agency: Department of Health and Human Services (HHS) - Substance Abuse and Mental Health Services Administration (SAMHSA) Passed Through Entity: Not applicable Federal Award Number: 1H79SM085136-01 Federal Award Year: August 31, 2021 – August 30, 2023 Compliance Requirement: Special Tests and Provisions – Sliding Fee Discounts 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, expense, and number of dependents in conjunction with the sliding fee schedule. Of the 25 patients selected for testing, we noted the following: - 4 patients were charged the incorrect sliding fee amount, which resulted in the Organization overcharging 2 patients by $10 each, while 2 patients were undercharged by $5 each. - 4 patients had no proof of income declaration and sliding fee application form on file. Due to an unsupported sliding fee discount, we were unable to determine if these 4 patients were eligible for the sliding fee and should have been charged the full amount totaling $523.48. Questioned Costs $513.48 in net undercharges for sliding fee patients sampled. Causes and Effect The potential cause for the above errors is as follows: - Error by staff in determining the patient’s ability to pay. - Lack of review and retention of sliding fee applications and income declaration forms. - Patients did not complete the required form necessary to determine the patient’s ability to pay. As a result, the determination of patient fees is not consistent with the sliding fee schedule. 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.