Audit 415633

Section III - Federal Award Findings and Questioned Costs Item 2025-002 - Special Tests and Provisions - U.S. Department of Health and Human Services, Health Center Program Cluster (Assistance Listing Number 93.224/93.527), FAIN # H8000410 and H8N53897, for FY 2025 - Material Weakness Criteria Health centers are required to have a corresponding schedule of discounts applied and adjusted on the basis of patients' ability to pay and their eligibility. A patient's eligibility to pay is determined on the basis of the official poverty guideline, as revised by DHHS (42 CFR Sections 51c, 107(b)(5), 56.108(b)(5) and 56.303(f)). The Center should be implementing and monitoring procedures to properly determine, calculate and review sliding fee discounts issued to patients in accordance with the Center's sliding fee scale. Statement of Condition While performing our audit, we noted that the Center did not properly determine the sliding fee discount category given to patients selected for testing based on the sliding fee scale in effect for the year ended December 31, 2025. Cause The condition can be attributed to human error and the lack of internal controls to review and ensure that the proper sliding fee documentation is being maintained and applied. Effect or Potential Effect The Center did not comply with the determination of sliding fee discounts based on the federal poverty guidelines in effect for the year ended December 31, 2025. In addition, the Center may not have properly calculated the sliding fee or discount given to the patients and the discount given, if any, may not have been based on the patient's ability to pay. Questioned Costs None Context While performing our audit, we noted that the Center did not properly determine the sliding fee discount category given to five out of 20 patients selected for testing based on the sliding fee scale in effect for the year ended December 31, 2025. Identification as a Repeat Finding This finding is a repeat finding - see 2024-001. Recommendation We recommend that proper training be given to employees at registration to ensure that the sliding fee discounts are monitored and reviewed by a supervisor on a periodic basis to ensure compliance with the sliding fee scale. In addition, management should conduct internal audits to ensure the sliding fee is calculated properly. Views of Responsible Official Management of the Organization agrees with the finding and has identified a need to strengthen the consistent application and documentation of the sliding fee discount program, including front-end staff processes related to patient eligibility, documentation, and collection of applicable fees, as well as back-end billing processes to ensure that sliding fee adjustments and write-offs are applied accurately and consistently. The Organization will implement a standardized training, monitoring, and reconciliation process to ensure appropriate administration of the sliding fee discount program from patient registration through final account reconciliation. All front desk/patient services staff will receive mandatory training on the sliding fee discount program.The billing/revenue cycle team will establish a back-end review process to ensure that accounts approved for the sliding fee discount program are adjusted appropriately. Furthermore, management will conduct routine audits of a sample of sliding fee discount program accounts to confirm compliance at both the front and back end. Audit findings will be reviewed with patient services and billing leadership, and any identified deficiencies will result in immediate correction and additional staff education as necessary. The Organization will monitor compliance on an ongoing basis to ensure that the corrective action is sustained and that eligible patients consistently receive the appropriate sliding fee discount.