Finding 1156757 (2024-002)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2024
Accepted
2025-09-30
Audit: 369094
Organization: Highland Health Providers (OH)

AI Summary

  • Core Issue: Errors were found in applying the sliding fee discount schedule, affecting patient billing based on their ability to pay.
  • Impacted Requirements: Compliance with 42 CFR 51c.3032 through 56.303g regarding sliding fee adjustments was not met due to incorrect system inputs.
  • Recommended Follow-Up: Implement a review process for sliding fee adjustments and have management regularly verify compliance with the updated flat rate discount policy.

Finding Text

Information on the federal program - Assistance Listing Number 93.224, Health Center Program Cluster from the U.S. Department of Health and Human Services, Federal Award No. 6 H80CS33657 for project periods September 1, 2022 through April 30, 2025. Criteria or specific requirement - Health centers must prepare and apply a sliding fee discount schedule that incorporates the provisions of 42 CFR 51c.3032 through 56.303g to ensure that amounts owed for health center services by eligible patients are adjusted (discounted) based on the patient’s ability to pay. Condition - The audit of the major federal program identified errors in the application of sliding fee adjustments. Cause - Various adjustments, including the sliding fee, were not applied appropriately due to incorrect inputs in the Health Center’s system. Additionally, manual inputs required to calculate the sliding fee discounts resulted in errors in application of the sliding fee scales. Effect or potential effect - The sliding fee adjustments were not appropriately applied. Questioned costs - Not applicable Context - Out of a population of 104 sliding fee adjustments, a sample of 11 adjustments were tested. Out of the 11 tested, 2 adjustments were incorrectly calculated based on the Health Center’s approved sliding fee scales and the patient’s sliding fee application. A non-statistical sampling methodology was used to select the sample. Identification as a repeat finding – Is a repeat finding. Recommendation - We recommend that the Health Center implement a review process for sliding fee and other adjustments applied in the billing system, including review for the sliding fee application and relating supporting documents. Additionally, we recommend that a member of management with an understanding of the Health Center’s billing and sliding fee policies regularly review a sample of sliding fee adjustments in comparison to the Health Center’s sliding fee policy. Views of responsible officials and planned corrective actions - The Health Center agrees with the finding. In 2024, the Health Center changed its sliding fee discount policy to be a flat rate discount rather than a percentage. The Health Center changed the policy to minimize future errors in the discount calculation. The 2 errors noted within the testing were for service dates prior to the policy change. The Health Center believes that the issue should be resolved going forward.

Corrective Action Plan

Planned Corrective Action: In 2024, the Health Center changed its sliding fee discount policy to be a flat rate discount rather than a percentage. The Health Center changed this policy to minimize future errors in the discount calculation. The 2 errors noted within the testing were for service dates prior to the policy change. The Health Center believes that the issue should be resolved going forward. Anticipated Completion Date: 12/31/2025 Responsible Contact Person: Meghann Ackley, Chief Financial Officer

Categories

Special Tests & Provisions

Other Findings in this Audit

  • 1156755 2024-002
    Material Weakness Repeat
  • 1156756 2024-002
    Material Weakness Repeat
  • 1156758 2024-003
    Material Weakness Repeat
  • 1156759 2024-003
    Material Weakness Repeat
  • 1156760 2024-003
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
93.224 Health Center Program (community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) $303,748
93.527 Grants for New and Expanded Services Under the Health Center Program $216,667
93.526 Grants for Capital Development in Health Centers $93,413