Finding Text
Finding 2023-002 Application of Sliding Fee Discount
Program
Information:
Federal Agency U.S. Department of Health and Human Services
Federal Assistance
Listing Number
93.224 and 93.527 Health Center Program Cluster
Award Number H80CS40219
Criteria [X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness
OMB 2 CFR 200, Subpart F Compliance Supplement, Part 4, Compliance
Requirement N, Special Tests and Provisions states, “Health centers must
prepare and apply a sliding fee discount schedule so that the amounts owed for
health center services by eligible patients are adjusted (discounted) based on the
patient’s ability to pay.”
Condition In our testing of 40 sliding fee discounts for health center patients qualifying for
reduced charge visits, we identified 1 instance where no application was
maintained. We also identified 6 instances where the incorrect sliding fee was
applied to the patient.
Cause The Center did not have a review process in place to verify eligible patients
completed the required application to receive a sliding fee discount and that each
application contained the required information. Additionally, the Center did not
verify the correct sliding fee discount was based on the Center’s sliding fee
scale.
Context The finding appears to be a systemic problem.
Effect Missing applications could indicate that patients who received a sliding fee
discount may not have been eligible. Additionally, the sliding fee discount could
be applied incorrectly and not in accordance with the Center’s policy.
Recommendation We recommend developing proper controls around obtaining and maintaining
sliding fee applications, verifying required patient information is present and
complete, and apply the sliding fee discount in accordance with written policy.
To ensure sliding fee discounts are properly calculated and documented, the
Center should increase the frequency of random reviews of its sliding fee
discount applications to help detect and correct errors or incomplete applications
on a timely basis. In addition, the Center should provide additional training of
staff involved in the application of sliding fee discounts.
View of responsible
officials and
planned corrective
action.
GVHC implemented the physical review and controls described in the 2022
audit response. Our efforts were largely successful as the missing application
was the only failure of the physical audit process we put in place. However, a
failure of our technology and billing software was revealed. Our plan it to:
1. Continue to provide frequent education and training for front-desk staff
to assist in preparation and required completion of the sliding fee
applications and proof of income.
2. Continue to identify patients who have exhausted their limited Medicaid
benefits and will now qualify for sliding fee scale for dental work.
3. Continue to review reports identifying patients with no end date
identified for their sliding fee scale. For identified accounts, determine
correct date and enter in the system.
4. Continue 100% audit of all sliding fee scale applications for accuracy of
calculation and presence of necessary paperwork. Provide direct
feedback to staff when errors are identified.
Integrate changes to billing software into the process when sliding fee scales are
adjusted and posted. Run reports of sliding fee scale discounts and audit for
correct calculation.