Finding 1151956 (2024-001)

Finding 2024.001: Special Tests and Provisions - Sliding Fee Scale Discounts - Significant Deficiency Federal Agency: U.S. Department of Health and Human Services Federal Program Names: Health Center Program Cluster Federal Assistance Listing Numbers: 93.224 and 93.527 Federal Award Identification Number and Year: H8000166 - 2024, H8K49695 - 2023 Criteria Health centers are required to have a corresponding schedule of discounts applied and adjusted on the basis of patients' ability to pay and their eligibility. A patient's eligibility to pay is determined on the basis of the official poverty guideline, as revised by DHHS (42 CFR Sections 51c, 107(b)(5),56.108(b)(5) and 56.303(f)). The Center should be implementing and monitoring procedures to properly determine, calculate and review slide fee discounts issued to patients in accordance with the Center's sliding fee scale. Condition The Center did not always calculate the proper sliding fee discount based on the Center's approved sliding fee discount policy or have the appropriate documentation. Cause The Center did not have adequate internal controls in place to effectively ensure that the patient received the correct sliding fee discount based on the Center's approved sliding fee discount policy. Effect or Potential Effect The Center did not comply with the appropriate Special Tests and Provisions rules and regulations as per the Uniform Guidance. Questioned Costs None Context A test of 40 slide fee discount transactions was performed and resulted in an instance of one slide fee discount that was not properly calculated based on an error that occurred due to a system configuration issue. Identification of Repeat Finding Not a repeat finding. Recommendation The Center should establish a system of internal controls to ensure that all patients receive the correct sliding fee discount. Views of Responsible Officials Upon review it was determined that a single CDT code within the Center’s practice management system was not set-up with the proper procedure class and was omitted from the sliding fee program maintenance schedule. The procedure class was subsequently corrected in the system. The Center has audited all CDT codes and has determined that there were no other errors. Additionally, the Center audited all D0274 charges since January 1, 2024, and determined that there were no other similar occurrences. Management agrees with the audit finding and will strengthen internal controls and accountability to correct the deficiency.