Finding Text
Health Center Program Cluster – Assistance Listing Nos. 93.224 and 93.527
U.S. Department of Health and Human Services
Award No. 6 H80CS00751-22-03, April 1, 2023 – March 31, 2024
Award No. 4 H8GCS47984-01-01, December 1, 2022 – December 31, 2023
Award No. 6 H8FCS41089‐01‐03, April 1, 2021 – March 31, 2024
Criteria or Specific Requirement – Special Tests and Provisions: Sliding Fee Discounts – 42 USC 254(k)(3)(g); 42 CFR sections 51c.303(g); and 42 CFR sections 56.303(f)
Condition – Sliding fee discounts applied to patient charges were inconsistent with the Organization’s sliding fee discount schedule.
Questioned Costs – None
Context – A sample of 25 encounters out of a population of approximately 54,288 encounters were tested and 4 instances of inappropriate sliding fee adjustments were identified. The sampling methodology used is not and is not intended to be statistically valid.
Effect – The patients’ responsibility for services rendered by the Organization was inconsistent with the stated sliding fee discount schedules.
Cause – The Organization’s sliding fee discount schedules are very nuanced and difficult to automate in the practice management system.
Identification as a repeat finding, if applicable – Not a repeat finding
Recommendation – The Organization should review the sliding fee discount policy and schedules to ensure compliance with the Health Center Program Compliance Manual while considering improvements that can be made for both patient and personnel understanding and increased accuracy of system-generated adjustments. The Organization should also continue educating personnel on the sliding fee discount program and consider implementing internal audits of sliding fee adjustments to monitor and identify specific areas for further improvements or training.
Views of responsible officials and planned corrective actions – The Organization is currently reviewing our sliding fee discount policy to switch from a percentage-based model to a flat fee model. This simplification should reduce our sliding fee adjustment errors, while maintaining compliance with the Health Center Program Compliance Manual. In addition, we will be implementing regular monitoring to ensure that patient accounts are accurate and reflect our posted sliding fee rates. Further, relevant staff participated in a training focused on CHC grants management matters in December 2024 and will continue to look for learning opportunities to support and challenge compliance matters.