Finding 1162972 (2025-001)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2025
Accepted
2025-11-25
Audit: 372572
Organization: Sterling Health Solutions, Inc. (KY)

AI Summary

  • Core Issue: The Health Center did not apply sliding fee discounts correctly for two patients, violating federal requirements.
  • Impacted Requirements: Compliance with 42 CFR, Part 51.303(f) and (g) regarding fee schedules and patient discounts.
  • Recommended Follow-Up: Enhance internal reviews and provide additional training for the revenue cycle team to prevent future errors.

Finding Text

Health Center Program Cluster; Federal Assistance Listing No. 93.224 and 93.527; Department of Health and Human Services; H8024168, budget period 6/1/2024 – 5/31/2025 Criteria or specific requirement: Special Tests and Provisions – 42 CFR, Part 51.303(f) and (g). Health Centers receiving funds under the Health Center Program Cluster are required to prepare a schedule of fees or payments for the provision of its services designed to cover its reasonable costs of operation and a corresponding schedule of discounts adjusted on the basis of the patient’s ability to pay, to make every reasonable effort, including the establishment of systems for eligibility determination, billing and collection, and to secure from patient payments for services in accordance with the schedule of fees and discounts. Condition: We noted during our testing of compliance with federal awards that the Health Center did not properly apply the sliding fee discounts approved by the board of directors for two patients out of a sample of 25 patients. Cause: The Health Center did not comply with their sliding fee policy on retaining supporting documentation and an error in inputting the family size information. Effect or potential effect: Discounts were not properly applied to patient accounts. Questioned cost: None Context: From a total of 7,499 sliding fee discounts for the period, 25 discounts were selected for testing. This sample was not, and was not intended to be, a statistically valid sample. The Health Center’s management did prepare a schedule of discounts adjusted on the basis of the patient’s ability to pay; such schedule was periodically updated and approved by the Health Center’s board of directors and the schedule was uploaded into the Health Center’s billing system. For two of the 25 accounts selected for testing, the account had an incorrect discount applied or lack of supporting documentation. Identification as a repeat finding, if applicable: Not a repeat finding. Recommendation: We recommend management continue their internal review process and increase training provided to their revenue cycle team members. Views of responsible officials and planned corrective actions: Management acknowledged the sliding fee adjustment errors. Management will add an additional layer of review over the application of the sliding fee scale. Further, the Health Center will continue their periodic reviews of sliding fee adjustments throughout the year for accuracy.

Corrective Action Plan

Sterling Health Solutions (SHS) acknowledges the errors identified and is committed to addressing the underlining reasons that caused them. SHS will review all applicable policies and provide additional training to ensure that all personnel responsible for and involved in the sliding fee discount program adequately demonstrate their understanding of the sliding fee discount application program. SHS will monitor Slide applications on a daily basis and complete, at a minimum, quarterly audits of each clinic’s Slide applications. SHS will provide ongoing training, as necessary, to address any concerns identified during the daily monitoring or quarterly audits.

Categories

Special Tests & Provisions Eligibility Matching / Level of Effort / Earmarking

Other Findings in this Audit

  • 1162971 2025-001
    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) $2.67M
93.912 US Department of Health and Human Services - Rural Communities Opiod Response Program - Medication Assisted Treatment Access $1.59M
93.268 IMMUNIZATION COOPERATIVE AGREEMENTS $131,025
93.527 GRANTS FOR NEW AND EXPANDED SERVICES UNDER THE HEALTH CENTER PROGRAM $56,261