Finding 1168715 (2023-002)

Material Weakness Repeat Finding
Requirement
P
Questioned Costs
-
Year
2023
Accepted
2026-01-11
Audit: 380731
Organization: State of Kosrae (FM)
Auditor: BCM LLC

AI Summary

  • Core Issue: The health center failed to verify income eligibility for sliding fee discounts, treating all patients as low-income without proper documentation.
  • Impacted Requirements: Compliance with the sliding fee discount schedule under CFDA 93.224 and 45 CFR Part 75 was not met, risking inaccurate patient charges.
  • Recommended Follow-Up: YSG should enforce timely submission of patient financial records and develop a comprehensive Sliding Fee Discount Schedule to ensure compliance.

Finding Text

Finding No.: 2023-002 Area: CFDA 93.224 Health Center Grant Inability to Verify Compliance with Sliding Fee Discount Requirements Criteria: Under the Health Center Program (CFDA 93.224), health centers are required to implement and apply a sliding fee discount schedule (SFDS) to adjust patient charges based on income and family size, ensuring access to affordable healthcare services for low-income individuals. The sliding fee discounts must be applied in accordance with the health center’s approved schedule. In addition, 45 CFR Part 75, Appendix XI (Compliance Supplement) requires auditors to review the sliding fee discount schedule and a sample of patient financial records to verify that discounts are appropriately calculated and applied based on income and family size. Condition: This finding was reported in the prior year and the same condition continued during the current audit period. During our fieldwork at Yap State Hospital, we noted that income eligibility determinations were not performed for patients as required by the grantor. The hospital treated the entire Yap State population as being below the poverty level, resulting in all patients automatically qualifying for sliding fee discounts. Documentation provided by Yap State Government (YSG) and the health center was limited to cash receipts reports. These reports did not include sufficient patient-level financial information, such as income and family size, to allow verification that sliding fee discounts were applied in accordance with program requirements. Cause: The health center did not provide the required patient financial records for services rendered during the audit period. Effect: Because patient financial records were not made available, we were unable to determine whether the health center complied with the sliding fee discount requirements of the Health Center Program. This condition increases the risk that patient charges may not be accurately or consistently adjusted, potentially limiting affordability for low-income patients and resulting in noncompliance with federal program requirements. Recommendation: We recommend that YSG work closely with the health center to establish and enforce procedures for the timely and complete submission of patient financial records for audit and compliance purposes. The health center should ensure that adequate documentation is maintained to support income and family size determinations and the proper application of sliding fee discounts. If necessary, YSG should seek guidance from the federal awarding agency to ensure compliance with program requirements. In addition, Yap State Government health centers should immediately develop, implement, and document a comprehensive Sliding Fee Discount Schedule in accordance with applicable federal regulations. Schedule of Findings and Questioned Costs, Continued Year Ended September 30, 2023 Finding No.: 2023-002 Area: CFDA 93.224 Health Center Grant Inability to Verify Compliance with Sliding Fee Discount Requirements Identification as a Repeat Finding: Yes Views of Responsible Officials: The State agreed with the finding. See the response and planned corrective actions in the Corrective Action Plan following the Schedule of Findings and Questioned Costs.

Corrective Action Plan

2023-02 We agree with this Finding. Henceforth, we will ask for the employment status of all new and continuing patients. Those who are employed will be required to provide their most recent W-2 form or their paycheck stub as proof of their income and eligibility for the sliding scale discount. This information will be kept in each patient’s file and will be updated on a regular basis to ensure the continued compliance of the WCHC to the discount policy. March 31, 2026 Ms. Irene Laabrug Chief, Division of Finance & Treasury (691) 350-2142 ilaabrug123@gmail.com

Categories

Eligibility

Programs in Audit

ALN Program Name Expenditures
15.875 ECONOMIC, SOCIAL, AND POLITICAL DEVELOPMENT OF THE TERRITORIES $12.64M
93.224 HEALTH CENTER PROGRAM (COMMUNITY HEALTH CENTERS, MIGRANT HEALTH CENTERS, HEALTH CARE FOR THE HOMELESS, AND PUBLIC HOUSING PRIMARY CARE) $1.83M
84.027 SPECIAL EDUCATION GRANTS TO STATES $535,226
93.268 IMMUNIZATION COOPERATIVE AGREEMENTS $106,698
93.959 BLOCK GRANTS FOR PREVENTION AND TREATMENT OF SUBSTANCE ABUSE $87,690
93.092 AFFORDABLE CARE ACT (ACA) PERSONAL RESPONSIBILITY EDUCATION PROGRAM $72,127
93.898 CANCER PREVENTION AND CONTROL PROGRAMS FOR STATE, TERRITORIAL AND TRIBAL ORGANIZATIONS $67,603
93.994 MATERNAL AND CHILD HEALTH SERVICES BLOCK GRANT TO THE STATES $60,422
15.904 HISTORIC PRESERVATION FUND GRANTS-IN-AID $43,846
59.006 8(A) BUSINESS DEVELOPMENT PROGRAM $37,388
93.788 OPIOID STR $36,396
10.664 COOPERATIVE FORESTRY ASSISTANCE $28,809
93.116 PROJECT GRANTS AND COOPERATIVE AGREEMENTS FOR TUBERCULOSIS CONTROL PROGRAMS $26,790
93.377 PREVENTION AND CONTROL OF CHRONIC DISEASE AND ASSOCIATED RISK FACTORS IN THE U.S. AFFILIATED PACIFIC ISLANDS, U.S. VIRGIN ISLANDS, AND P. R. $23,765
93.110 MATERNAL AND CHILD HEALTH FEDERAL CONSOLIDATED PROGRAMS $21,814
93.217 FAMILY PLANNING SERVICES $20,401
93.889 NATIONAL BIOTERRORISM HOSPITAL PREPAREDNESS PROGRAM $13,114
93.958 BLOCK GRANTS FOR COMMUNITY MENTAL HEALTH SERVICES $3,038
93.069 PUBLIC HEALTH EMERGENCY PREPAREDNESS $400
93.243 SUBSTANCE ABUSE AND MENTAL HEALTH SERVICES PROJECTS OF REGIONAL AND NATIONAL SIGNIFICANCE $370
93.991 PREVENTIVE HEALTH AND HEALTH SERVICES BLOCK GRANT $0