Audit 413294

Finding 2025-001 – Incorrect Application of Sliding Fee Discounts Assistance Listing Number (ALN): 93.224 and 93.527 Assistance Listing Program Title: Health Center Program Cluster Federal Agency: U.S. Department of Health and Human Services (HHS) Passed Through Entity: Not applicable Federal Award Numbers: H80CS10609, H8HCS46150, Q8JCS54499 Federal Award Year: May 1, 2024 to April 30, 2025 May 1, 2025 to April 30, 2026 September 1, 2024 to December 31, 2025 December 1, 2024 to November 30, 2026 Compliance Requirement: Special Tests and Provisions – Sliding Fee Discounts Criteria or Specific Requirements Section N (1) Special Tests and Provisions – Sliding Fee Discounts of Part 4 Agency Program Requirements of the Health Center Program Cluster, states that “Health centers must have a schedule of fees or payments for the provision of their health services consistent with locally prevailing rates or charges and designed to cover their reasonable costs of operation. They are also required to have a corresponding schedule of discounts applied and adjusted based on the patient’s ability to pay. The patient’s ability to pay is determined based on the official poverty guidelines, as revised annually by the U.S. Department of Health and Human Services (HHS). The poverty guidelines are issued each year in the Federal Register and HHS maintains a web page that provides the poverty guidelines.” Condition UMMA determines patient fees based on a patient’s income, expenses, and number of dependents in accordance with its sliding fee schedule. Of the 40 patient files selected for testing, we identified three instances in which in which patients were charged incorrect sliding fee amounts, resulting in patient overcharges totaling $20. In two instances, clinic staff inadvertently assigned incorrect poverty levels to patients, causing the Electronic Medical Record (EMR) system to calculate incorrect sliding fee amounts and resulting in overcharges totaling $10 ($5 per patient). In the third instance, a patient was charged an incorrect sliding fee, resulting in an overcharge of $10. This finding is a repeat of prior year Finding 2024-001. Management notes that the identified errors occurred prior to the implementation of the corrective action plan developed in response to the prior year’s findings. Although management implemented corrective actions following the completion of the 2024 audit, the exceptions identified during the current year indicate that the controls established over the determination and application of sliding fee discounts had not yet been fully effective throughout the audit period. Questioned Costs None Causes and Effect The exceptions appear to have resulted from a combination of the following factors: • Errors by staff in properly utilizing the sliding fee schedule; • Opportunities to enhance supervisor review process; and • The need for continued staff training Such errors may result in an inaccurate assessment of a patient’s ability to pay and the application of incorrect sliding fee discounts, which could lead to patients being charged amounts that are not in accordance with program requirements. Recommendation We recommend that UMMA continue its efforts to strengthen controls over the determination and application of sliding fee discounts. These efforts should include ongoing staff training, reinforcement of supervisory review procedures, and periodic monitoring of sliding fee determinations so that exceptions can be identified and corrected promptly. Management should also continue evaluating EMR system workflows and related validation controls to reduce the risk of incorrect poverty level assignments and fee calculations. These measures should support consistent application of UMMA’s sliding fee schedule and ongoing compliance with the Agency Program Requirements of the Health Center Program Cluster. Views of Responsible Officials and Planned Corrective Actions Management agrees with the findings and will implement the following actions to prevent future occurrences: • Immediate training for all front desk staff to ensure accurate application of the sliding fee process; • Continuous internal audits to monitor compliance with the sliding fee discount program guidelines as stated in UMMA’s policies and procedures; and • Upon satisfactory completion of samples audited, UMMA will continue to provide quarterly training and periodic audits to ensure continued compliance. Responsible Official Alejandra Murillo, Chief Financial Officer Expected Implementation Date December 31, 2025