Finding 1157564 (2024-001)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2024
Accepted
2025-09-30
Audit: 369793
Auditor: Wipfli LLP

AI Summary

  • Core Issue: Inconsistent application of the sliding fee discount schedule led to errors in discounts for patients who did not qualify.
  • Impacted Requirements: Health centers must follow internal controls to ensure accurate calculations and proper documentation of sliding fee discounts.
  • Recommended Follow-Up: Implement robust internal controls to review and approve all sliding fee determinations and maintain proper documentation.

Finding Text

Criteria Health centers must prepare and apply a sliding fee discount schedule (SFDS) so that the amounts owed for health center services by eligible patients are adjusted (discounted) based on the patient’s ability to pay. The health center must also implement internal controls to ensure that the calculation is determined correctly and is supported. Condition Wipfli reviewed 40 sliding fee charges to test if the amount charged was calculated properly based on the patients’ income level, family size and in compliance with Outreach Community Health Center's’ sliding fee policy. Wipfli noted in 4 of the 40 cases, a sliding fee discount was given to a patient who did not qualify for the a sliding fee discount or support was not maintained for the discount given, and in 2 of the 40 cases, Wipfli noted the amount of the sliding fee adjustment applied to the patient's account was incorrectly determined. Cause and Effect Outreach Community Health Centers did not consistently follow the Organization’s policies for approving, documenting and calculating charges for services when using the sliding fee scale and sliding fee discounts were applied in error to certain accounts due to staff incorrectly marking them as sliding fee patients. Auditor’s Recommendation Implement effective internal controls that ensure that all policies and procedures related to the sliding fee are followed and that sliding fee discounts are reviewed to determine that the proper discounts were applied and documentation was retained or documented. Internal controls would include review and approval on all sliding fee determinations and a review of discounts given to sliding fee patients in order to detect sliding fee discounts given in error. View of Responsible Officials Management agrees with the findings and has committed to a corrective action plan.

Corrective Action Plan

Staffing & Structure: A dedicated Patient Financial Counselor (PFC) position was created and filled on November 27, 2023. A second staff member was transitioned into a PFC role on April 7, 2024, to augment the team. Training & Education: A dedicated Patient Financial Counselor (PFC) position was created and filled on November 27, 2023. A second staff member was transitioned into a PFC role on April 7, 2024, to augment the team. Process & Technology Improvements: Monthly Audits: Implement ongoing monthly audits of sliding fee applications to proactively identify and address errors. Staff will receive targeted training based on audit findings. System Enhancement: Awaiting implementation of the Epic Patient Financial Module (released August 2024) to enable real-time tracking and improve outreach to eligible patients.

Categories

Internal Control / Segregation of Duties

Programs in Audit

ALN Program Name Expenditures
93.224 Consolidated Health Centers (community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) $3.16M
14.235 Supportive Housing Program $543,843
93.150 Projects for Assistance in Transition From Homelessness (path) $311,710
93.667 Social Services Block Grant $136,890
93.958 Block Grants for Community Mental Health Services $96,645
14.267 Continuum of Care Program $41,819
93.268 Immunization Cooperative Agreements $30,637