Finding 1166826 (2025-002)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2025
Accepted
2025-12-29

AI Summary

  • Core Issue: The EMR system calculates sliding fee discounts using outdated Federal Poverty Guidelines (FPGs) based on when patient information was entered, not the date of service.
  • Impacted Requirements: Discounts should reflect the most recent FPGs at the time services are provided, as per the Health Center Program Compliance Manual.
  • Recommended Follow-Up: Management is working with the EMR provider to implement changes; ensure updates align with the release of the 2026 FPGs.

Finding Text

DEPARTMENT OF HEALTH AND HUMAN SERVICES 2025-002 Other Matter Special Tests and Provisions: Sliding Fee Discounts – Federal Poverty Guidelines Condition: During our audit, we selected a sample of 25 records for patients treated during the audit period to determine whether patient charges were appropriately adjusted based on income and family size by applying the Clinic’s board approved sliding fee discount scales. Although the Clinic timely updated its board-approved sliding fee scales to reflect the most recent FPGs, the electronic medical record (EMR) system does not automatically re-evaluate a patient’s discount level using the current FPGs at the date of service. Instead, the system locks the discount calculation to the FPG in effect on the date the patient’s income and family-size information was originally entered into the EMR. During our procedures, four sliding fee discounts did not use the correct FPGs to determine the sliding fee discount. Criteria: Sliding fee discounts should be determined based on the most recent FPGs at the date of service. Cause: The EMR uses the FPGs as of the date the sliding fee discount information was entered into the software instead of the FPG as of the date of service. Example: A patient’s sliding fee information is entered December 1, 2024. If the patient receives services during 2025, the EMR continues to calculate the sliding fee discount based on the 2024 FPG (when the sliding fee information was inputted into the software). Effect: Sliding fee discounts are calculated using outdated FPGs. Since the FPGs do not change significantly, most patient’s will still be within the same FPG range and charged the appropriate sliding fee discount, so there is no material (or significant) impact to the financial statements or compliance over the Clinic’s major federal program. Recommendations: While using outdated FPGs for sliding fee discounts will not result in a material misstatement to the financial statements or material noncompliance due to the nature of the issue, the Clinic should address to ensure the sliding fee discount program is being operated as required by the Health Center Program Compliance Manual and intended by the board of directors. View of Responsible Officials and Planned Corrective Actions: Management agrees with the other matter. Planned corrective action is in progress. Management has reached out to their EMR provider to discuss an implementation strategy to address the condition. Implementation of corrective action is expected to occur once the 2026 FPGs are released.

Corrective Action Plan

View of Responsible Officials and Planned Corrective Actions: Management agrees with the other matter. Planned corrective action is in progress. Management has reached out to their EMR provider to discuss an implementation strategy to address the condition. Implementation of corrective action is expected to occur once the 2026 FPGs are released.

Categories

Special Tests & Provisions

Other Findings in this Audit

  • 1166825 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) $944,708
93.527 GRANTS FOR NEW AND EXPANDED SERVICES UNDER THE HEALTH CENTER PROGRAM $2,813