Finding Text
2023 – 006 Federal agency: U.S. Department of Health and Human Services Federal program title: Health Centers Cluster Assistance Listing Numbers: 93.224/93.527 Award Period: Varying project and budget periods: 2/1/22 – 1/31/23, 2/1/23 – 1/31/24, 4/1/21 – 3/31/23, 12/1/22 – 12/31/23 Type of Finding: • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per Title 42 Chapter 1 Subchapter D Section 51C303(f) and (g), health centers must have a schedule of fees or payments for the provision of their health services consistent with locally prevailing rates or charges and designed to cover their reasonable costs of operations. They are also required to have a corresponding schedule of discounts applied and adjusted on the basis of the patient's ability to pay. Condition: During our audit testing surrounding the sliding fee discount policy, we noted two instances where an error was made in the sliding fee determination, or insufficient documentation was retained to support adjustment calculation. Questioned costs: None. Context: 1 out of 25 sliding fee adjustments tested was not calculated properly in accordance with the Organization's policy. For this individual the sliding fee adjustment category was determined incorrectly, and a larger adjustment was provided than what the correct determination would have provided. For 1 out of 25 sliding fee adjustments tested, the sliding fee application was not able to be provided, so there was not sufficient documentation to support the sliding fee determination. Cause: Manual errors and insufficient review or oversight in the sliding fee adjustment calculation process. Effect: A patient paid the incorrect amount for an encounter as the sliding fee adjustment had been calculated incorrectly. For another patient encounter, the Organization is not able to provide sufficient supporting organization for the sliding fee adjustment determined. No specific instances of noncompliance with the grant requirements were identified, although there were instances of noncompliance with the Organization's own policies. The lack of internal controls over these compliance requirements, however, creates a risk for noncompliance. Recommendation: We recommend the organization have a review process over determinations to ensure accuracy and provide training as needed to mitigate risk of future errors. We also recommend reviewing procedures in place for retaining documentation for sliding fee applications to ensure sufficient detail is retained according to policy. View of responsible officials: No disagreement with the finding. Management will review sliding fee policies and procedures in place to improve oversight and provide training to the team members conducting the patient intake and reviewing sliding fee applications.