Audit 410075

Finding No. 2025-001: Special Tests and Provisions (Sliding Fee Discounts) Federal Awarding Agency: U.S. Department of Health and Human Services Federal Program Title: Health Center Program Cluster Awards: ALN 93.224 Consolidated Health Centers Criteria: Health centers must prepare and apply a sliding fee discount schedule (SFDS) so that the amounts owed for health center services by eligible patients are adjusted (discounted) based on the patient’s ability to pay. A patient's ability to pay is determined on the basis of the Federal Poverty Guidelines, as revised by the Department of Health and Human Services (DHHS). Condition: The Center’s Board-approved sliding fee discount schedule was not configured correctly within the eClinicalWorks (eCW) billing system. As a result, patient sliding fee discounts were calculated using an incorrect schedule, and discounts were not applied in accordance with the Center’s approved policy. Cause: The Center did not have adequate internal controls in place to ensure that the approved sliding fee discount schedule was accurately entered and maintained in the billing system, or that discounts generated by the system were reconciled to the approved schedule. Effect: Because the sliding fee discount schedule was misconfigured at the system level, the exceptions are not limited to the transactions selected for testing — the incorrect schedule had the potential to affect all patient encounters to which a sliding fee discount was applied during the year. The Center was therefore unable to demonstrate that sliding fee discounts were determined in accordance with the Health Center Program requirements and its Board-approved schedule, and the total financial effect on patient discounts could not be quantified. Questioned Costs: None. The noncompliance relates to the calculation of patient sliding fee discounts and did not result in costs charged to the federal award that are questioned; however, as noted above, the effect on patient discounts could not be quantified. Context/Sampling: A statistically valid sample of 40 sliding fee discount transactions was tested to determine whether discounts were calculated in accordance with the Organization's approved sliding fee discount schedule. Testing identified 5 instances (12.5%) in which the sliding fee discount was calculated incorrectly. Repeat Finding: No Recommendation: The Organization should establish internal controls to ensure the Board-approved sliding fee discount schedule is accurately entered and maintained in the eCW billing system, including a secondary review of any changes to the schedule and a periodic reconciliation of system-generated discounts to the approved schedule. View of Responsible Officials and Planned Corrective Action: Management agreed with the audit finding and has strengthened internal controls and accountability to correct the deficiency.