Audit 386157

Finding No. 2025-001 - Sliding Fee Determination and Related Patient Billing U.S. Department of Health and Human Services Assistance Listing Number 93.224 Consolidated Health Centers Program Cluster Criteria: All section 330-funded health centers must prepare and apply a sliding fee discount schedule (SFDS), which adjusts amounts owed for health center services by eligible patients based on the patient’s ability to pay. The National Health Services Corps (NHSC) statute mandates that NHSC-approved sites “not deny requested health care services and shall not discriminate in the provision of services to an individual because the individual is unable to pay for the services.” It stipulates, “the entity shall prepare a schedule of discounts (including, in appropriate cases, waivers) to be applied to the payment of such fees or payments. In preparing the schedule, the entity shall adjust the discounts on the basis of a patient’s ability to pay.” (42 U.S.C. § 254g) Condition: As part of our compliance testing procedures for the HRSA 330 grant program, we tested sixty patients billed under a sliding fee discount schedule. Of the patients tested, four (7%) were found to have exceptions in the amount charged to the patient. Cause: Based on the audit procedures performed, in four instances, the patient was not charged at the discount applicable to the patient’s income level. Effect: Four patients, out of a sample of sixty patients, were inaccurately billed for the services provided by Rural Health Corporation of Northeastern Pennsylvania. Two patients were overbilled by an amount of $26. Two patients were underbilled by a total amount of $146. Questioned Costs: None Repeat finding: None Recommendation: Rural Health Corporation of Northeastern Pennsylvania has established policies and controls which did not operate effectively in these instances. We recommend that management strengthen and expand the procedures for review of manual data inputs and enhance their training programs on sliding fee scale processes and procedures. View of the Responsible Official: RHC of NEPA has taken significant steps to improve and rectify their sliding fee deficiency over its last 3 audits. RHC of NEPA has improved from 2 consecutive material weakness findings to having substantial improvement and reduced its status to a significant deficiency. It is important to note that 2 of the outstanding claims identified had timely sliding fee documents completed, however they were out of compliance due to human error of calculation of the sliding fee percentage. Education and internal audits which were implemented throughout the organization which have driven the marked improvement will continue to be disseminated throughout the organization. Clearly based on the improvement that has occurred, current processes and level of attention are the correct items to rectify and become fully compliant with sliding fee requirements. These policies will be the focus of additional training with a separate session being dedicated to the updated sliding fee implementation in February of 2026.