Audit 368617

Assistance Listing Number: 93.224 and 93.527 Name of Federal Agency: Department of Health and Human Services, HRSA Program Title: Health Center Program Compliance Requirement: Special Tests and Provisions – Sliding Fee Discounts Pass-through Entity: N/A Federal Grant/Contract Number and Grant Year: 5 H80C00097-23-00 (2024), 6 H80CS00097-23-14 (2024), 1 H8GCS47591-01-00 (2022 and 2023), 1 H8LCS50961-01-00 (2023 and 2024) Finding Type: Noncompliance and Significant Deficiency in Internal Control Known Questioned Costs: $279 Condition: The Organization did not follow the correct processes of review and approval of the application of the sliding fee scale. - Failure to provide approval of one of the sliding fee scale applications. - One patient listed in the sliding fee scale population did not have an application. - One sliding fee scale claim was incorrectly applied to the slide as the patient had insurance. Criteria: 2 CFR section 200.303 requires that nonfederal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the nonfederal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Health centers must prepare and apply a sliding fee discount schedule, so that the amounts owed for health center services by eligible patients are adjusted based on the patient’s ability to pay (42 U.S.C 254b(k)(3)(G)(i)). The patient’s ability to pay is based on the official poverty guidelines, as revised annually by the U.S. Department of Health and Human Services (42 U.S.C 9902(2). Cause: Failure to apply the sliding fee correctly, as noted in the encounters above, was due to improper staff training or failure to properly monitor the process. Perspective: Out of the forty items sampled, 2 instances contained exceptions resulting in noncompliance. The total dollar value of the exceptions in the sample was $279 out of a total dollar amount of $8,454 sampled. Extrapolated over the population dollar value of $11,803,872, the projected error was $389,549 likely questioned costs. The sample was not statistically valid. Effect: The Organization could be incorrectly billing for services Recommendation: Staff should be consistently trained in how patients should complete the intake forms, including the sliding fee scale application, and require patients complete the form appropriately, including refusal to provide information, if applicable. Staff should also be consistently trained in what documentation is considered sufficient to support income identified as well as verify the application is consistent with the documentation and, when needed, clearly document the reasons for inconsistency. Staff should make every effort to obtain documentation of patient income in accordance with internal policies and procedures. Views of Responsible Officials and Planned Corrective Actions: See Corrective Action Plan