Audit 409865

Finding No. 2025 001: Use of Incorrect Sliding Fee Schedule (SFS) in Determination of Sliding Fee Amount Assistance Listing Number: 93.224 and 93.527 Assistance Listing Program Title: Health Center Program Cluster Federal Agency: U.S. Department of Health and Human Services (HHS) - Health Resources and Services Administration Pass Through Entity: Not applicable Federal Award Number: 6 H80CS00142-24-24 Federal Award Year: January 1, 2025 to December 31, 2025 Compliance Requirement: Special Tests and Provisions – Sliding Fee Discounts Criteria or Specific Requirement Pursuant to 42 CFR 51c.303(f), health centers are required to prepare a schedule of fees or payments for the provision of its services designed to cover its reasonable costs of operation and a corresponding schedule of discounts adjusted on the basis of the patient's ability to pay provided that such schedule of discounts shall provide for a full discount to individuals and families with annual incomes at or below those set forth in the poverty guidelines updated periodically in the Federal Register by the U.S. Department of Health and Human Services under the authority of 42 U.S.C. 9902(2). Additionally, the HRSA Health Center Program Compliance Manual, Chapter 9: Sliding Fee Discount Program, requires health centers to ensure that their sliding fee discount program is based on current Federal Poverty Level (FPL) guidelines and is implemented consistently and in accordance with board-approved policies. Specifically, Chapter 9 requires that health centers apply the most current approved sliding fee schedule when determining patient eligibility and discounts, and that such schedules be updated and implemented timely following governing board approval. Identified Condition Of the 26 patients selected for sliding fee discounts testwork, we noted 9 patients whereby the calculation of the sliding fee amount incorrectly utilized the 2023 approved sliding fee schedule instead of the 2024 or 2025 sliding fee schedules, as applicable. This did not result an overcharge or undercharge to the patients. Cause The 2025 and 2024 sliding fee schedules were approved by the Board on March 27, 2025 and May 23, 2024, respectively. However, such sliding fee schedules were not activated in the EPIC system (patient billing system) and therefore, the EPIC system continued to utilize the 2023 sliding fee schedule. Management is currently researching the cause of this issue and has reached out to the EPIC Analyst to obtain additional information regarding the configuration and update process of the approved sliding fee schedule within EPIC. Effect The use of an outdated sliding fee schedule may result in: • Inaccurate determination of patient eligibility; • Incorrect calculation of the sliding fee amount charged to the patient, and • Noncompliance with federal program requirements. Questioned Cost None. Recommendation We recommend that management implement procedures to ensure that the sliding fee schedule is updated in the EPIC system promptly following Board approval. Additionally, management should establish a review procedure to verify that the correct sliding fee schedule is applied in the system for all patient eligibility determinations. Management’s Views and Corrective Action Plan To minimize the likelihood of recurrence, management will implement a final sign-off step requiring review and approval by a manager or supervisor to confirm that the sliding fee schedule update has been successfully completed in the EPIC system. Additionally, management is coordinating with the EPIC Analyst to better understand the EPIC system configuration and update processes related to Sliding fee schedule updates and ensure that future updates are properly applied and functioning as intended. Personnel responsible for implementation: Robert Young, VP Patient Financial Services Date of implementation: May 1, 2026