Finding 1166211 (2025-002)

Material Weakness Repeat Finding

Requirement

Questioned Costs

Year

2025

Accepted

2025-12-22

Audit: 377177

Organization: Heartland Medical Clinic, Inc., D/b/a Heartland Community Health Center (KS)

Auditor: COHNREZNICK LLP

AI Summary

Core Issue: The Organization failed to apply sliding fee discounts correctly based on patients' income levels.
Impacted Requirements: Compliance with federal guidelines for determining patient eligibility and discount calculations.
Recommended Follow-Up: Strengthen internal controls to ensure accurate application of sliding fee discounts and monitor compliance.

Finding Text

Finding 2025.002: Special Tests and Provisions - Sliding Fee Discounts - Significant Deficiency Grantor: U.S. Department of Health and Human Services Federal Program Names: Health Center Program Cluster, Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care, Grants for New and Expanded Services under the Health Center Program, COVID-19 Grants for New and Expanded Services under the Health Center Program Federal Assistance Listing Numbers: 93.224 and 93.527 Federal Award Identification Number and Year: H80CS24170-13-00 and 2024 Criteria Health centers are required to have a corresponding schedule of discounts applied and adjusted on the basis of patients' ability to pay and their eligibility. A patient's eligibility to pay is determined on the basis of the official poverty guideline, as revised by DHHS (42 CFR Sections 51c, 107(b)(5), 56.108(b)(5) and 56.303(f)). The Organization should be implementing and monitoring procedures to properly determine, calculate and review sliding fee discounts issued to patients in accordance with the Organization's sliding fee scale. Condition The Organization did not always appropriately apply the sliding fee discount based on income levels. Cause The Organization did not have adequate internal controls in place to effectively ensure that patients receive the correct sliding fee discount. Effect or Potential Effect The Organization did not comply with the appropriate rules and regulations as per the Uniform Guidance. Questioned Costs None. Context A test of 40 slide fee discount transactions was performed and resulted in one instance of a sliding fee discount not being properly calculated based on the respective patient family size and income or was not in agreement with the supporting documentation. Our sample was a statistically valid sample. Identification as a Repeat Finding Not a repeat finding. Recommendation The Organization should strengthen internal controls in place to effectively ensure that patients receive the correct sliding fee discount. Views of Responsible Officials and Planned Corrective Actions Management agrees with the audit finding and will strengthen internal controls and accountability to correct the deficiency.

Corrective Action Plan

Finding 2025.002 - Sliding Fee Scale Discount Recommendation The Organization should strengthen internal controls in place to effectively ensure that patients receive the correct sliding fee discount. Action Taken • Monthly Audits o The Front Office Coordinators at each location will routinely audit sliding fee verification on a monthly basis to verify that information has been captured and recorded correctly and all proof of income documentation is received. These monthly audits will be adopted as standard protocol and procedure for front office operations, effective January 2025. Any findings through the audit process will be reported to the COO. At least five patient charts will be audited monthly. o In addition, the Revenue Cycle Manager will also review audit findings or summaries to ensure adequate adjustment to patient accounts to correlate with the patient's eligibility status. • Staff Training o Although Heartland has offered periodic sliding fee scale procedure training, administration will be scheduling additional training with a focus on required documentation and proper analysis and implementation of sliding fee discounts. o COO and Revenue Cycle Manager will review, implement and update standard operating procedure for sliding fee scale verification. o Employees will receive a copy of the sliding fee scale policy and sign that they have read the material. o Front office employees at all locations will complete a sliding fee schedule competency check-off sheet that will be reviewed by the Front Office Coordinators and Revenue Cycle Manager.

Other Findings in this Audit

1166209 2025-002

Material Weakness Repeat
1166210 2025-002

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)	$2.24M
93.526	GRANTS FOR CAPITAL DEVELOPMENT IN HEALTH CENTERS	$289,792
93.217	FAMILY PLANNING SERVICES	$239,170
93.268	IMMUNIZATION COOPERATIVE AGREEMENTS	$82,069
93.917	HIV CARE FORMULA GRANTS	$54,286
93.243	SUBSTANCE ABUSE AND MENTAL HEALTH SERVICES PROJECTS OF REGIONAL AND NATIONAL SIGNIFICANCE	$43,127
93.527	GRANTS FOR NEW AND EXPANDED SERVICES UNDER THE HEALTH CENTER PROGRAM	$40,272
93.165	GRANTS TO STATES FOR LOAN REPAYMENT	$30,000