Finding Text
Criteria – The HRSA Compliance Manual requires federally qualified health centers (FQHCs) to establish and maintain a sliding fee discount program to ensure that services are accessible to patients regardless of their ability to pay. Eligibility must be based solely on income and family size, supported by appropriate documentation. Under Uniform Guidance (2 CFR §200.303), non-federal entities must establish and maintain effective internal controls over compliance with federal statutes, regulations, and program requirements. The OMB Compliance Supplement (Part 4, Health Center Program Cluster) further emphasizes that health centers must document income and family size to properly apply sliding fee discounts and must consistently implement the approved discount schedule. Condition and Description – During our testing of compliance with the sliding fee discount program, we identified deficiencies in the application and documentation of the sliding fee discount schedule. Of 10 patient encounters selected for review, 6 patient files did not contain a registration form to support determination of sliding fee eligibility. In addition, although the Organization’s policy requires retention of two paystubs for each patient to verify income, only one paystub was maintained in several patient records. Further, 4 patient files reviewed did not contain documentation of household member information, which is required to calculate family size for eligibility determination. These deficiencies reflect noncompliance with the Organization’s policies and federal program requirements and may result in patients not being charged in accordance with their ability to pay. Questioned Costs – Unknown. Cause/Effect –. The Organization did not obtain or retain adequate documentation of patient income, family size, and registration forms to support eligibility determinations. Without this information, compliance with the sliding fee discount requirements could not be demonstrated, creating the risk that discounts were not applied appropriately and federal program requirements were not met