Condition: During audit testing of the Sliding Fee Discount Program for the fiscal year ended June 30, 2025, NeoMed Center, Inc. identified deficiencies in the documentation, retention, and supervisory review of patient eligibility determinations. Specifically, patient financial information was upda...
Condition: During audit testing of the Sliding Fee Discount Program for the fiscal year ended June 30, 2025, NeoMed Center, Inc. identified deficiencies in the documentation, retention, and supervisory review of patient eligibility determinations. Specifically, patient financial information was updated in a manner that overwrote prior eligibility evaluations, resulting in the loss of historical eligibility records. In addition, patient files were not consistently closed or retained in accordance with established policies and federal program requirements. These conditions reflected weaknesses in internal controls over eligibility documentation and supervisory oversight, which increased the risk of inconsistent application of the sliding fee scale, noncompliance with HRSA Health Center Program and Ryan White Part C requirements, inaccurate patient billing adjustments, and potential misstatement of patient service revenue. Planned Corrective Action: Management implemented corrective actions to strengthen internal controls over the Sliding Fee Discount Program and ensure sustained compliance with applicable federal requirements. Policies and procedures governing eligibility determinations and sliding fee discount applications were revised to require preservation of historical eligibility records, standardized documentation, and proper file‑closure practices. Clear supervisory review responsibilities were established to ensure eligibility determinations and fee assessments are reviewed for accuracy, completeness, and compliance. Targeted training was provided to staff responsible for patient registration, eligibility determinations, and fee assessments to ensure consistent application of the sliding fee scale and adherence to federal program requirements. In addition, management implemented periodic internal reviews of patient files to verify compliance with documentation, retention, and eligibility reassessment requirements, and to promptly identify and remediate any deficiencies. These corrective actions were designed to enhance internal control effectiveness, support accurate financial reporting, and prevent recurrence of the identified condition. Key internal controls include: • Revised and strengthened Sliding Fee Discount Program policies and procedures. • Implemented controls to preserve historical eligibility determinations and documentation. • Established standardized eligibility documentation and file‑closure processes. • Defined supervisory review responsibilities and escalation procedures. • Provided targeted training to eligibility and registration staff. • Implemented periodic internal reviews of patient files to ensure compliance. Monitoring: Management will conduct periodic supervisory reviews of patient eligibility determinations and sliding fee discount applications beginning April 1st, 2026, to ensure compliance with established policies and federal program requirements. Monitoring will include sample testing of patient files to verify proper documentation, preservation of historical eligibility records, and timely reassessments. Results of monitoring activities will be documented and reviewed by management, and corrective actions will be implemented as needed to address any deficiencies identified. Responsible Official: Jose A. Guzman Machuca Time frame: This condition was resolved in March 2026 upon the implementation of revised policies, enhanced documentation controls, staff training, and supervisory review procedures