Audit 415471

Information on Federal Program: U.S. Department of Health and Human Services – Health Center Program Cluster AL# 93.224 Criteria Section 42 USC 254b(k)(3)(E), (F), and (G); 42 CFR sections 51c.303(e), (f), and (g); and 42 CFR sections 56.303(e), (f), and (g)) requires that health centers provide discounted fees for individuals and families with incomes above 100% and at or below 200% of the federal poverty guidelines. Condition For the year ended January 31, 2026, we requested the supporting documentation for a sample of patient visits with discounted fees under the sliding fee program to support that patients were eligible for the discount and that it was applied in accordance with the Center’s internal policies and procedures. During testing of 40 patient accounts subject to the Sliding Fee Discount Program, we identified 2 instances in which the sliding fee discount was not applied correctly. As a result, the patients were billed amounts that differed from what they should have been charged under the organization's approved sliding fee discount schedule. Cause Internal controls, while designed appropriately, were not implemented consistently to allow for the detection and correction of these types of errors. Effect or potential effect The sliding fee discount program may not be operating in accordance with federal regulations. Questioned costs None noted. Recommendation The entity should revisit their current internal control policies and provide additional training for staff to ensure compliance with documented controls. Additional research should be done into the cause of the incorrectly applied sliding fee discounts to determine if this was a system issue to determine the best course of action. If this is determined to be a manual adjustment done incorrectly, we recommend additional training be provided to staff as well as additional controls to review the manually applied discounts for accuracy. Views of Responsible Officials and Planned Corrective Actions Management will work to ensure that the SFS discount applications are completed accurately and that the SFS discounts are recorded accurately in the system by auditing the SFS applications and verifying the SFS in the system matches the SFS application. In addition, Management will audit a sample of the SFS discounts on a monthly basis to assure the SFS is applied correctly. Management will also provide additional training to staff as needed and provide further guidance on the internal SFS policies and procedures. Indication of Repeat finding This is a repeat finding of finding 2025-003 from the prior year.

Information on Federal Program: U.S. Department of Health and Human Services – Health Center Program Cluster AL# 93.224 Criteria Section 42 USC 254b(k)(3)(E), (F), and (G); 42 CFR sections 51c.303(e), (f), and (g); and 42 CFR sections 56.303(e), (f), and (g)) requires that health centers provide discounted fees for individuals and families with incomes above 100% and at or below 200% of the federal poverty guidelines. Condition During testing of 40 patient files, we noted deficiencies in the organization's controls over the review and monitoring of sliding fee discount applications. Specifically:  Nine patient files did not contain documentation demonstrating that the application review and audit form completion were performed by separate individuals as required by policy.  Seven audit forms contained incomplete, inaccurate, or missing information. Cause Management's monitoring controls over the sliding fee discount application review process were not operating effectively to ensure required documentation was completed, segregation of duties was maintained, and audit forms were accurately completed. Effect or potential effect The organization was unable to demonstrate consistent compliance with established policies designed to ensure the accuracy and integrity of sliding fee discount eligibility determinations. Inadequate documentation and lack of segregation of duties increase the risk that eligibility determinations, discount calculations, or patient classifications may not be appropriately reviewed and errors may not be detected in a timely manner. Questioned costs None noted. Recommendation We recommend management strengthen controls over the sliding fee discount application review process by:  Reinforcing documentation requirements for application reviews and audit forms.  Ensuring review and audit responsibilities are performed by separate individuals and documented accordingly.  Implementing periodic supervisory reviews of completed audit forms to verify accuracy and completeness.  Providing additional training to staff responsible for eligibility determinations and quality assurance reviews. Views of Responsible Officials and Planned Corrective Actions Management will work to ensure that the SFS discount applications are completed accurately and that the SFS discounts are recorded accurately in the system by auditing the SFS applications and verifying the SFS in the system matches the SFS application. In addition, Management will audit a sample of the SFS discounts on a monthly basis to assure the SFS is applied correctly. Management will also provide additional training to staff as needed and provide further guidance on the internal SFS policies and procedures. Indication of Repeat Finding This is not a repeat finding.