Audit 409999

Finding Number: 2025 002 Finding Type: Significant deficiency in internal controls over compliance and nonmaterial noncompliance related to Special Tests and Provisions Information on the Federal Program: Program Name: Health Center Program Cluster (AL numbers 93.224 and 93.527) Grant Awards: H80CS04210 20 from May 1, 2024 through April 30, 2025 and H80CS04210 21 from May 1, 2025 through April 30, 2026 Agency: U.S. Department of Health and Human Services, Health Resources and Services Administration Pass Through Entity: N/A Criteria: In accordance with Section 330(k)(3)(G) of the Public Health Services Act (42 U.S. Code § 254b), as an FQHC, the Organization must have a sliding fee discount program in which patient charges are adjusted based on the patient’s ability to pay. Condition: Through testing a statistically valid sample of 25 individual patient balances, we identified four instances in which the sliding fee discount applied was inconsistent with the Organization's policy. Specifically, in two instances, sliding fee adjustments were applied based on individual procedure codes rather than the date of service. In one additional instance, an incorrect sliding fee adjustment was applied to the patient balance. Collectively, these three errors resulted in patients being charged $311 more than required under the Organization's sliding fee discount program. We also identified one patient who received a sliding fee discount without an active sliding fee application for the applicable date of service and was therefore not eligible for the $204 discount. Cause: The Organization lost the dental biller who performed a review of 100% of dental sliding fee adjustments. Upon the individual's departure, responsibility for this review was not assumed by other members of the billing team. Effect: Sliding fee discounts may not be consistently applied in accordance with the Organization's policy, resulting in potential noncompliance with federal program requirements if errors are not timely identified and corrected. Questioned Costs: None Repeat Finding: No Recommendation: We recommend the Organization reevaluate its monitoring procedures over the sliding fee discount program. The monitoring process should include clearly assigned responsibility for review, defined review frequency and sample sizes, and consideration of system-specific risks. Given the increased level of manual processing for dental transactions, monitoring should include enhanced testing of dental sliding fee adjustments. Views of a Responsible Official and Corrective Action Plan: Management agrees with the finding. See corrective action plan.