Management agrees with the finding and recommendation regarding sliding fee discount compliance and has taken corrective actions to address the identified issues. For non-pharmacy in-scope services, a portion of the exceptions identified resulted from the implementation of the Organization’s new OCH...
Management agrees with the finding and recommendation regarding sliding fee discount compliance and has taken corrective actions to address the identified issues. For non-pharmacy in-scope services, a portion of the exceptions identified resulted from the implementation of the Organization’s new OCHIN Epic electronic health record system effective January 1, 2025. During the initial system build and configuration process, certain CPT codes that should have been designated as eligible for sliding fee discounts were not appropriately mapped as “slideable” services within the EHR. Upon discovery, a ticket was submitted to OCHIN Epic on March 15, 2026, to correct the system configuration. Affected patient accounts were subsequently identified and corrected retroactively. Additionally, during the EHR setup process, the adjustment code title “SFS Discount” was inadvertently applied to employee discount adjustments rather than the correct “Employee Discount Adjustment” designation required under Organization policy. While there was no financial impact to patient balances or charges, certain employee discounts may have been incorrectly reflected within reporting categories. Upon identifying the issue, a correction ticket was submitted to OCHIN Epic on May 21, 2025, to update the system configuration. At the time, billing staff believed the system correction would apply both prospectively and retroactively; however, during the audit process it was determined that historical transactions existing prior to the EHR correction also required manual retroactive adjustment within the system. Since that time, affected accounts have been reviewed and corrected retroactively, and management has implemented additional procedures to ensure future system correction tickets are evaluated for any required historical manual corrections. For in-house pharmacy dispensing fees, the Organization implemented Pharmacy Policy PH-113, In-House Sliding Fee Policy, which was approved by the Board of Directors in July 2025 as part of corrective actions related to the prior year audit process. Staff training on the revised policy and procedures was completed during July and August 2025. The Organization notes that all pharmacy exceptions identified during the fiscal year 2025 audit related to prescriptions dispensed prior to implementation of PH-113. Based on external audit testing of post-implementation prescriptions and ongoing internal self-audits, management believes the revised policy, training, and monitoring processes have substantially corrected the identified issues. Management will continue performing periodic internal audits, staff education, retroactive corrections when necessary, and ongoing monitoring of sliding fee discount application within both the EHR and pharmacy systems to ensure continued compliance with Health Center Program requirements. In addition, following HRSA program guidance and discussions communicated in March 2026 regarding application of sliding fee discounts to pharmacy dispensing fees, the Organization is evaluating revisions to Pharmacy Policy PH-113 to align future dispensing fee practices with current HRSA guidance and operational best practices. The Organization will continue maintaining internal monitoring, periodic self-audits, and corrective action procedures to identify and remediate potential issues timely. Anticipated Completion Date: Corrective actions related to identified fiscal year 2025 sliding fee discount exceptions, retroactive account corrections, EHR configuration updates, staff training, and implementation of enhanced monitoring procedures were substantially completed by May 31, 2026. Ongoing internal audits, monitoring, and policy evaluations will continue as part of normal compliance operations. Responsible Individuals: CFO, Pharmacy Director, Billing Supervisor, Revenue Cycle Staff, Clinical Leadership, and Information Technology/EHR Support Staff