Audit 411958

Grantee 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 (discounted) based on the patient's ability to pay. The Organization adopted a Sliding Fee Discount Schedule based on current Federal poverty guidelines; however, they failed to consistently document the patient's assessment for the discount and retain the patient's application. 3 out of 25 patients tested did not have documentation of the sliding fee discount assessment. We were unable to determine whether the sliding fee discount was properly applied to these patients. The effect is reportable non-compliance with the Special Tests compliance requirement for this grant. Further, the Organization has a significant deficiency in internal controls over compliance. The Organization's internal control over compliance was properly designed to ensure patients were assessed for ability to pay; however, it was not operating effectively during the period under audit. It is recommended that the Organization ensure that the Sliding Fee Discount Form is completed for every patient on their initial visit, updated annually, and included within their patient record. The form documents the patient's household income and eligible dependents to properly assess their ability to pay based upon the Federal poverty guidelines. Futher, it is recommended that the Organization develop a monitoring tool to detect when this control may not be operating effectively.

Grantees are required to correctly determine, use, and record program income as a condition of the grant. It was noted that non-Ryan White B patients were being included within the grant's program income during the year. 7 out of 25 patients selected for testing were determined to be mis-classified within the program income of the Ryan White Part B program (RWB). The effect is reportable non-compliance with the program income compliance requirement for this grant, as well as, a material weakness in internal controls over compliance. Patients are being mis-classified within the medical billing process as RWB patients. As a result, program income is being overstated by the additional patients' income. The cause of the mis-classification is being researched. It is recommended that the Organization research the cause of the misclassification and develop a preventative internal control to ensure that patient income is being correctly classified initially. Further, it is our recommendation that the Organization develop a monitoring control to detect and correct when errors have occurred in the RWB classification of patients.