Finding 1157136 (2025-001)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2025
Accepted
2025-09-30

AI Summary

  • Core Issue: The Organization lacks proper documentation for sliding fee applications, affecting compliance with federal grant requirements.
  • Impacted Requirements: Federal provisions mandate accurate identification of patient payment ability and adherence to the sliding fee schedule.
  • Recommended Follow-Up: Implement a review process to ensure all sliding fee applications are filed and verified before applying discounts to patients.

Finding Text

Finding Number: 2025-001 Finding Type: Internal Control over Compliance – Special Tests and Provisions (Sliding Fee Discounts) Information on the Federal Program: Cluster Name: Health Center Cluster – 330 Grant Federal Awards: H80CS00311 Federal Agency: U.S. Department of Health and Human Services Criteria: Federal grant compliance provisions require that the Organization correctly identify a patient's ability to pay and that the rates for services be adjusted accordingly based on the sliding fee schedule. The Organization is required to follow its sliding fee policy when providing discounts to eligible patients. Condition: The Organization did not have a record of the sliding fee application used to determine sliding fee eligibility for six patients selected for testing. Questioned Costs: None Repeat Finding: No Cause and Effect: The Organization does not have procedures in place to ensure that sliding fee applications are electronically scanned and filed. Sliding fee applications are reviewed by one individual and a sliding fee level determination is entered into the patient’s medical records and the Organization’s billing software, but there is no documented process for a second individual at the Organization to verify that the application was filed and the sliding fee level for that patient was appropriately entered into the patient’s medical records. Lack of strict enforcement of the policy of sliding fee eligibility determination and compliance may have resulted in the Organization providing discounted services greater to or less than the appropriate amounts to beneficiaries. Recommendation: The Organization should establish a review process for all patient information entered into the Organization’s billing software to ensure that a sliding fee application is on file and the sliding fee applied to the patient is in line with the information verified on the application. Views of Responsible Official and Corrective Action Plan Management acknowledges and understands this finding. A response to the finding is noted in the Corrective Action Plan on page 40.

Corrective Action Plan

Response to FY2025 Audit Finding: Impact: "Lack of policy enforcement may have resulted in the Organization providing discounted services greater to or less than the appropriate amounts to beneficiaries" Why: 1. Were staff not consistently collecting the required income and family size documentation? 2. Was training not comprehensive enough or did staff turnover lead to a knowledge gap? 3. Is the Organizations policy or process for documenting income unclear or not consistently enforced? 4. Was there a system in place to audit patient files internally to catch documentation errors? 5. Is the culture of compliance not strong enough to prioritize consistent documentation? Action: 1. Update/Revise sliding fee policy and procedure to clearly define acceptable documentation process for income verification and annual re-evaluation 2. Create and deliver comprehensive training to all relevant staff (front desk, enrollment specialist, and billing) 3. Implement ongoing monitoring – • Establish a new scheduled internal audit process to regularly review a sample of patient documentation for sliding fee documentation compliance. • Establish metrics to track progress, such as percentage of patient files with complete sliding fee documentation, for new and annual sliding fee applications. 4. Once all actions are complete and the issue is resolved, document these improvements to continue the cycle of compliance 5. Continue to audit files at random to ensure documentation compliance continues

Categories

Special Tests & Provisions Eligibility Internal Control / Segregation of Duties

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) $3.53M
93.493 Congressional Directives $673,242
93.110 Maternal and Child Health Federal Consolidated Programs $176,580
93.150 Projects for Assistance in Transition From Homelessness (path) $115,921
93.527 Grants for New and Expanded Services Under the Health Center Program $87,512
93.778 Medical Assistance Program $33,448
93.898 Cancer Prevention and Control Programs for State, Territorial and Tribal Organizations $30,451
93.977 Sexually Transmitted Diseases (std) Prevention and Control Grants $1,330