Finding 1163241 (2024-002)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2024
Accepted
2025-12-01

AI Summary

  • Core Issue: Sliding fee discounts applied to patient charges were not in line with the Organization’s established policy.
  • Impacted Requirements: Compliance with sliding fee discount regulations (42 USC 254(k)(3)(g); 42 CFR sections 51c.303(g); 42 CFR sections 56.303(f)).
  • Recommended Follow-Up: Ensure all staff understand and follow the sliding fee scale policy, and implement procedures to guarantee discounts are applied correctly.

Finding Text

Health Center Program Cluster Assistance Listing Numbers 93.224 and 93.527 U.S. Department of Health and Human Services Health Center Cluster – Award Identifying No. H80CS00139 Northeast Valley Health Corporation Criteria or Specific Requirement – Special Tests and Provisions: Sliding Fee Discounts (42 USC 254(k)(3)(g); 42 CFR sections 51c.303(g); and 42 CFR sections 56.303(f)) Condition – Sliding fee discounts applied to patient charges were inconsistent with the Organization’s sliding fee discount policy. Cause – The Organization did not comply with their sliding fee policy. Effect – Sliding fee discounts were given to patients that were inconsistent with the Organization’s sliding fee discount policy. Questioned costs – None Context – A sample of 25 encounters were tested out of the total population of 148,394 encounters. The sampling methodology used is not and is not intended to be statistically valid. Four patients received a sliding fee adjustment that was inconsistent with the approved policy based on their income documentation. Identification as a repeat finding – Not a repeat finding. Recommendation – It is recommended that management continue to ensure all personnel understand the sliding fee scale policy and adhere to the requirements and guidelines set forth in the policy. Procedures should be implemented to ensure that eligible patients receive discounts in accordance with the sliding fee scale and the Health Center Program Compliance Manual.

Corrective Action Plan

Management agrees with the finding that sliding fee discounts must be applied consistently and in accordance with our approved policy. We are committed to ensuring access to care while maintaining compliance with HRSA program requirements. Planned Corrective Actions: To strengthen compliance with our sliding fee discount policy, East Valley Community Health Center has implemented several corrective measures. Re-training for intake and billing staff began in April 2025 and is ongoing as part of our quarterly training cycle, In addition, we are currently reviewing our sliding fee discount policy and procedures to ensure they are clear, consistently applied, and aligned with HRSA guidance and the Health Center Program Compliance Manual. Monthly audits of patient encounters involving sliding fee adjustments began in October 2024 by the billing department and are now a permanent component of our internal compliance process. Audit results are reviewed by the Revenue Cycle Manager and shared with Clinic Managers, Front Office Leads, and Senior Leadership to ensure accountability and prompt corrective action when needed. The CFO is responsible for overseeing these processes and ensuring that all compliance measures are implemented effectively.

Categories

Special Tests & Provisions

Other Findings in this Audit

  • 1163238 2024-002
    Material Weakness Repeat
  • 1163239 2024-002
    Material Weakness Repeat
  • 1163240 2024-002
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
93.914 HIV EMERGENCY RELIEF PROJECT GRANTS $693,799
21.027 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $502,047
93.940 HIV PREVENTION ACTIVITIES HEALTH DEPARTMENT BASED $322,037
93.527 GRANTS FOR NEW AND EXPANDED SERVICES UNDER THE HEALTH CENTER PROGRAM $230,584
93.224 HEALTH CENTER PROGRAM (COMMUNITY HEALTH CENTERS, MIGRANT HEALTH CENTERS, HEALTH CARE FOR THE HOMELESS, AND PUBLIC HOUSING PRIMARY CARE) $223,640
93.217 FAMILY PLANNING SERVICES $204,601
93.918 GRANTS TO PROVIDE OUTPATIENT EARLY INTERVENTION SERVICES WITH RESPECT TO HIV DISEASE $102,259