Audit 339892

Finding 2024-001 – Sliding Fee Discount Program Federal Agency: U.S. Department of Health and Human Services Federal Program: Consolidated Health Centers Cluster AL Number: 93.224 / 93.527 Award Number: H80CS28351 Award Year: 2024 Repeat Finding: Yes Type of Finding: Significant Deficiency in Internal Control over Compliance and Noncompliance Criteria: Per Title 42 Chapter 1 Subchapter D Section 51c303(f)(g), “Health centers must have a schedule of fees or payments for the provision of their health services consistent with locally prevailing rates or charges designed to cover their reasonable costs of operation and a corresponding schedule of discounts adjusted on the basis of the patient’s ability to pay” and “Make every reasonable effort, including the establishment of systems for eligibility determination, billing, and collection.” Condition: During our special testing related to the Organization’s sliding scale, it was determined that the Organization did not consistently follow the sliding fee schedule in place. This occurred in three of the forty sampled patients. Cause: Review procedures were not followed within the Organization which caused issues in consistent application of the sliding schedule in accordance with the Organization’s policy. Effect: Potential that a patient would not receive the appropriate sliding fee discount or would receive a discount without meeting the discount criteria. Recommendation: We recommend the continued improvement of the process of billing encounters and analyzing claims to maximize the Organization’s program income and maintain compliance with the Sliding Fee Discount Program. Management’s Response: See Corrective Action Plan.

Finding 2024-001 – Sliding Fee Discount Program Federal Agency: U.S. Department of Health and Human Services Federal Program: Consolidated Health Centers Cluster AL Number: 93.224 / 93.527 Award Number: H80CS28351 Award Year: 2024 Repeat Finding: Yes Type of Finding: Significant Deficiency in Internal Control over Compliance and Noncompliance Criteria: Per Title 42 Chapter 1 Subchapter D Section 51c303(f)(g), “Health centers must have a schedule of fees or payments for the provision of their health services consistent with locally prevailing rates or charges designed to cover their reasonable costs of operation and a corresponding schedule of discounts adjusted on the basis of the patient’s ability to pay” and “Make every reasonable effort, including the establishment of systems for eligibility determination, billing, and collection.” Condition: During our special testing related to the Organization’s sliding scale, it was determined that the Organization did not consistently follow the sliding fee schedule in place. This occurred in three of the forty sampled patients. Cause: Review procedures were not followed within the Organization which caused issues in consistent application of the sliding schedule in accordance with the Organization’s policy. Effect: Potential that a patient would not receive the appropriate sliding fee discount or would receive a discount without meeting the discount criteria. Recommendation: We recommend the continued improvement of the process of billing encounters and analyzing claims to maximize the Organization’s program income and maintain compliance with the Sliding Fee Discount Program. Management’s Response: See Corrective Action Plan.

Finding 2024-001 – Sliding Fee Discount Program Federal Agency: U.S. Department of Health and Human Services Federal Program: Consolidated Health Centers Cluster AL Number: 93.224 / 93.527 Award Number: H80CS28351 Award Year: 2024 Repeat Finding: Yes Type of Finding: Significant Deficiency in Internal Control over Compliance and Noncompliance Criteria: Per Title 42 Chapter 1 Subchapter D Section 51c303(f)(g), “Health centers must have a schedule of fees or payments for the provision of their health services consistent with locally prevailing rates or charges designed to cover their reasonable costs of operation and a corresponding schedule of discounts adjusted on the basis of the patient’s ability to pay” and “Make every reasonable effort, including the establishment of systems for eligibility determination, billing, and collection.” Condition: During our special testing related to the Organization’s sliding scale, it was determined that the Organization did not consistently follow the sliding fee schedule in place. This occurred in three of the forty sampled patients. Cause: Review procedures were not followed within the Organization which caused issues in consistent application of the sliding schedule in accordance with the Organization’s policy. Effect: Potential that a patient would not receive the appropriate sliding fee discount or would receive a discount without meeting the discount criteria. Recommendation: We recommend the continued improvement of the process of billing encounters and analyzing claims to maximize the Organization’s program income and maintain compliance with the Sliding Fee Discount Program. Management’s Response: See Corrective Action Plan.

Finding 2024-001 – Sliding Fee Discount Program Federal Agency: U.S. Department of Health and Human Services Federal Program: Consolidated Health Centers Cluster AL Number: 93.224 / 93.527 Award Number: H80CS28351 Award Year: 2024 Repeat Finding: Yes Type of Finding: Significant Deficiency in Internal Control over Compliance and Noncompliance Criteria: Per Title 42 Chapter 1 Subchapter D Section 51c303(f)(g), “Health centers must have a schedule of fees or payments for the provision of their health services consistent with locally prevailing rates or charges designed to cover their reasonable costs of operation and a corresponding schedule of discounts adjusted on the basis of the patient’s ability to pay” and “Make every reasonable effort, including the establishment of systems for eligibility determination, billing, and collection.” Condition: During our special testing related to the Organization’s sliding scale, it was determined that the Organization did not consistently follow the sliding fee schedule in place. This occurred in three of the forty sampled patients. Cause: Review procedures were not followed within the Organization which caused issues in consistent application of the sliding schedule in accordance with the Organization’s policy. Effect: Potential that a patient would not receive the appropriate sliding fee discount or would receive a discount without meeting the discount criteria. Recommendation: We recommend the continued improvement of the process of billing encounters and analyzing claims to maximize the Organization’s program income and maintain compliance with the Sliding Fee Discount Program. Management’s Response: See Corrective Action Plan.

Finding 2024-001 – Sliding Fee Discount Program Federal Agency: U.S. Department of Health and Human Services Federal Program: Consolidated Health Centers Cluster AL Number: 93.224 / 93.527 Award Number: H80CS28351 Award Year: 2024 Repeat Finding: Yes Type of Finding: Significant Deficiency in Internal Control over Compliance and Noncompliance Criteria: Per Title 42 Chapter 1 Subchapter D Section 51c303(f)(g), “Health centers must have a schedule of fees or payments for the provision of their health services consistent with locally prevailing rates or charges designed to cover their reasonable costs of operation and a corresponding schedule of discounts adjusted on the basis of the patient’s ability to pay” and “Make every reasonable effort, including the establishment of systems for eligibility determination, billing, and collection.” Condition: During our special testing related to the Organization’s sliding scale, it was determined that the Organization did not consistently follow the sliding fee schedule in place. This occurred in three of the forty sampled patients. Cause: Review procedures were not followed within the Organization which caused issues in consistent application of the sliding schedule in accordance with the Organization’s policy. Effect: Potential that a patient would not receive the appropriate sliding fee discount or would receive a discount without meeting the discount criteria. Recommendation: We recommend the continued improvement of the process of billing encounters and analyzing claims to maximize the Organization’s program income and maintain compliance with the Sliding Fee Discount Program. Management’s Response: See Corrective Action Plan.

Finding 2024-001 – Sliding Fee Discount Program Federal Agency: U.S. Department of Health and Human Services Federal Program: Consolidated Health Centers Cluster AL Number: 93.224 / 93.527 Award Number: H80CS28351 Award Year: 2024 Repeat Finding: Yes Type of Finding: Significant Deficiency in Internal Control over Compliance and Noncompliance Criteria: Per Title 42 Chapter 1 Subchapter D Section 51c303(f)(g), “Health centers must have a schedule of fees or payments for the provision of their health services consistent with locally prevailing rates or charges designed to cover their reasonable costs of operation and a corresponding schedule of discounts adjusted on the basis of the patient’s ability to pay” and “Make every reasonable effort, including the establishment of systems for eligibility determination, billing, and collection.” Condition: During our special testing related to the Organization’s sliding scale, it was determined that the Organization did not consistently follow the sliding fee schedule in place. This occurred in three of the forty sampled patients. Cause: Review procedures were not followed within the Organization which caused issues in consistent application of the sliding schedule in accordance with the Organization’s policy. Effect: Potential that a patient would not receive the appropriate sliding fee discount or would receive a discount without meeting the discount criteria. Recommendation: We recommend the continued improvement of the process of billing encounters and analyzing claims to maximize the Organization’s program income and maintain compliance with the Sliding Fee Discount Program. Management’s Response: See Corrective Action Plan.