Finding 1163543 (2025-001)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2025
Accepted
2025-12-05

AI Summary

  • Core Issue: The Organization failed to consistently apply its sliding fee discount policy, leading to potential inaccuracies in service discounts for patients.
  • Impacted Requirements: Compliance with federal grant provisions (CFDA 93.224) regarding patient ability to pay and sliding fee schedule adherence.
  • Recommended Follow-Up: Provide employee training on sliding fee requirements and conduct regular audits of transactions to ensure compliance.

Finding Text

2025-001 Sliding Fee Discount Determination CFDA Number: 93.224 Program: Community Health Center Cluster Agency: US Department of Health and Human Services Compliance Requirement: N- Special Tests and Provisions Repeat Finding: Yes – see prior year finding 2024-001 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. Finding/ Condition: In our sample of 40 tested items, 8 samples patient information was unavailable due to changes in electronic health records. Questioned Cost: None. Effect: 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. Cause: Inadequate understanding of the sliding fee program requirements and Organization policies by employees involved in sliding fee determination and billing. Recommendation: Training should be provided to employees on the sliding fee program requirements. The Organization should perform regular audits of sliding fee transactions to identify weaknesses in compliance. Views of Responsible Officials and Corrective Action Plan: The Organization agrees with the finding and will implement additional controls to ensure that this does not recur. Please refer to the corrective action plan on page 32.

Corrective Action Plan

2025-001 Sliding Fee Discount Determination Name of Contact Person: Interim Chief Financial Officer: Shigeyuki Murota, Patient Accounts Manager: George Ward Corrective Action: San Francisco Medical Center Outpatient Improvement Programs, Inc. d/b/a Equity Health will: - Update the Sliding Fee Discount Program (SFDP) policies, procedures, and forms for better clarity and tracking. - Continue to perform monthly internal audits of sliding fee transactions and document audit findings, corrective actions, and report results to leadership. - Retrain current staff quarterly based on the monthly internal audit results. - Train all new staff at new hire orientations. - Validate staff understanding through annual knowledge checks and competency assessments. - Integrate SFDP compliance into staff performance evaluations. - Maintain centralized log of all SFDP applications and determinations. Proposed Completion Date: December 31, 2025

Categories

Special Tests & Provisions Eligibility

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) $645,532
93.527 GRANTS FOR NEW AND EXPANDED SERVICES UNDER THE HEALTH CENTER PROGRAM $371,574
93.918 GRANTS TO PROVIDE OUTPATIENT EARLY INTERVENTION SERVICES WITH RESPECT TO HIV DISEASE $129,094