Finding 1166285 (2023-002)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2023
Accepted
2025-12-23
Audit: 377361

AI Summary

  • Core Issue: Patients eligible for sliding fee discounts were either not given discounts or received them incorrectly.
  • Impacted Requirements: Non-compliance with sliding fee discount policy as outlined in 42 CFR regulations.
  • Recommended Follow-up: Ensure staff understand the sliding fee scale policy, implement procedures for proper discount application, and maintain documentation of patient eligibility.

Finding Text

Health Center Program Cluster – Assistance Listing Numbers 93.224 and 93.527 U.S. Department of Health and Human Services Award No. 5 H80CS04226-18-00 Program Year 2023 Criteria or Specific Requirement – Special Tests and Provisions: Sliding Fee Discounts – 42 CFR 245(k)(3)(g); 42 CFR section 51c.303(g) and 42 CFR section 56.303(f). Condition – Patients who were eligible for sliding fee discounts under the Organization’s policy were not given sliding fee discounts or received sliding fee discounts inconsistent with the policy. Cause – The Organization did not comply with their sliding fee discount policy. Effect or potential effect – Improper sliding fee discounts were given and appropriate documentation was not maintained for all sliding fee discounts given. Questioned costs – None Context – A sample of 40 patients were tested out of the total population of 50,510 encounters. The sampling methodology used was not, and was not intended to be, statistically valid. Of the 40 transactions tested, 4 were determined to include errors in the application of the sliding fee discount program and policy. Identification as a repeat finding – Repeat finding of finding 2022-003 Recommendation – The Organization should 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. Patient files should include documentation of eligibility to receive sliding fee scale discounts.

Corrective Action Plan

Management acknowledges the finding. We will conduct mandatory training sessions for all relevant personnel to ensure a clear understanding of the Sliding Fee Discount Program requirements and policy. Training will include proper documentation practices, eligibility verification, and procedures for applying discounts consistently. We will review and update our sliding fee discount policy to ensure clarity, consistency, and compliance with regulatory requirements. We will provide an annual review and obtain board approval of the Sliding Fee Discounting Program scheduled on an annual basis. Regular internal audits will be conducted to review the application of sliding fee discounts and identify any discrepancies before external audits. Results of internal audits will be shared with management, and corrective actions will be taken as necessary. We will assess the feasibility of implementing system controls or automated alerts within our electronic health record (EHR) and billing systems to reduce errors in discount applications. Additional oversight measures may be introduced to ensure all eligible patients receive the correct discount in accordance with policy guidelines. The above corrective actions are currently being implemented.

Categories

Special Tests & Provisions Eligibility

Other Findings in this Audit

  • 1166282 2023-002
    Material Weakness Repeat
  • 1166283 2023-002
    Material Weakness Repeat
  • 1166284 2023-002
    Material Weakness Repeat
  • 1166286 2023-003
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
93.696 CERTIFIED COMMUNITY BEHAVIORAL HEALTH CLINIC EXPANSION GRANTS $1.07M
93.243 SUBSTANCE ABUSE AND MENTAL HEALTH SERVICES PROJECTS OF REGIONAL AND NATIONAL SIGNIFICANCE $548,983
93.224 HEALTH CENTER PROGRAM (COMMUNITY HEALTH CENTERS, MIGRANT HEALTH CENTERS, HEALTH CARE FOR THE HOMELESS, AND PUBLIC HOUSING PRIMARY CARE) $442,400
93.323 COVID-19 EPIDEMIOLOGY AND LABORATORY CAPACITY FOR INFECTIOUS DISEASES (ELC) $378,488
93.788 OPIOID STR $349,564
93.959 BLOCK GRANTS FOR PREVENTION AND TREATMENT OF SUBSTANCE ABUSE $344,168
93.527 GRANTS FOR NEW AND EXPANDED SERVICES UNDER THE HEALTH CENTER PROGRAM $93,105
93.526 COVID-19 GRANTS FOR CAPITAL DEVELOPMENT IN HEALTH CENTERS $40,968
14.871 SECTION 8 HOUSING CHOICE VOUCHERS $35,931