Finding Text
Agency: U.S. Department of Health and Human Services
Assistance Listing Number: Health Center Program Cluster: 93.527 and 93.224
Program: Health Center Program Cluster; Grants for New and Expanded Services under the Health Center Program and Health Centers Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care)
Condition: The Organization did not have adequate and effective controls over compliance in place as it relates to applying the sliding fee discount. We found two (2) instances where an individual was not appropriately charged based on the sliding fee policy in place.
Criteria: Uniform Guidance requires that controls are implemented to ensure the Organization is in compliance with special tests and provisions. This includes charging the appropriate sliding fee discount based on the Organization's policy.
Questioned costs: Two errors were identified during our testing. The amount of questioned costs cannot be determined.
Context: A sample of 40 individuals were selected and tested for compliance with the Organization's sliding fee policy. Two known compliance errors were found during testing of the 40 individuals.
Effect: Noncompliance with application of the Organization's sliding fee discount went undetected due to a lack of effective controls over compliance.
Cause: Management has indicated that system limitations and lapses in internal communication led to the mis-keyed information not being identified during the internal control review process.
Recommendation: We recommend management review their controls over compliance relating to the Organization's compliance with the sliding fee discount to ensure discounts are appropriately charged, reviewed timely and management maintains documentation of the review.
Management's response: Before the audit testing, management discovered there were situations where the sliding fee wasn't being correctly applied. Discounts were being calculated by staff because the system calculations were wrong.
The Sliding Fee Scale system rebuild has undergone successful testing and is now in the process of being implemented. Management has suggested adjustments to the sliding fee scale to guarantee accurate calculation of patient balances. The board has already approved those changes, and the updated Sliding Fee Scale involves removing the percentage-based charges and setting fixed payments for nominal and minimum fees per visit.
The system rebuild for the Sliding Fee Scale has already been tested and is being rolled out. Alternatively, management has proposed changes to the sliding fee scale to ensure that the system will be able to properly calculate the amount due from patients by taking away the percentage due and making the nominal and minimum charges a flat amount per visit. These policy changes will make the application of the sliding fee scale easier to manage for the system, staff, and patients.