Finding 1169208 (2025-002)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2025
Accepted
2026-01-15

AI Summary

  • Core Issue: PHC failed to accurately calculate sliding fee discounts for patients, leading to non-compliance with federal guidelines.
  • Impacted Requirements: Health centers must follow specific criteria for determining discounts based on patients' ability to pay, as outlined by DHHS.
  • Recommended Follow-Up: PHC should implement stronger internal controls to ensure accurate calculations and proper documentation of sliding fee discounts.

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 (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: H8000133 - 2025 and 2024, H8L50678 - 2024, H8H46190 - 2023 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)). PHC should be implementing and monitoring procedures to properly determine, calculate and review sliding fee discounts issued to patients in accordance with PHC's sliding fee scale. Condition PHC did not always calculate the proper sliding fee discount based on approved policies or have adequate documentation on file. Cause PHC did not have adequate internal controls in place to effectively ensure that patients received the correct sliding fee discount and have adequate documentation on file. Effect or Potential Effect PHC did not comply with the appropriate Special Tests and Provisions rules and regulations as per the Uniform Guidance in 2025. Questioned costs None. Context A test of 40 sliding fee discount transactions was performed and resulted in one instance of an incorrect sliding fee calculation, eight instances of inadequate documentation on file to support the sliding fee calculation and three instances of lack of review and approval. Our sample was a statistically valid sample. Identification of Repeat Finding This finding is a repeat finding (see prior year Finding 2024.001) Recommendation PHC should establish a system of internal controls to ensure that all sliding fee discounts are properly calculated and supported based on family size and income. Views of Responsible Officials Management agrees with the audit finding and will strengthen internal controls and accountability to correct the deficiency.

Corrective Action Plan

Section III Federal Award Findings and Questioned Costs 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 Item 2025 002 – Special Tests Recommendation The Center should establish a system of internal controls to ensure that all slide fee discounts are properly calculated based on family size and income. Repeat Finding Yes Action Taken The Finance Department will take the following steps to enhance the slide fee discounts process: 1. Policy Revision: the health center will revise its Sliding Fee Discount Policy to ensure alignment with HRSA requirements, including accurate discount calculation methodologies, annual updates to the sliding fee scale, and proper utilization of NextGen system functionality to support implementation 2. Staff Training: the health center will provide comprehensive training to all relevant staff on the revised Sliding Fee Discount Policy and procedures. 3. Training will emphasize correct discount calculations, required documentation, and income verification processes. A recurring training program will be implemented to ensure ongoing compliance for both new hires and existing employees. 3. Retrospective Review: the health center will conduct a retrospective review of patient files for the current fiscal year to confirm that all sliding fee discounts are appropriately supported by required documentation. Any identified discrepancies will be corrected in a timely manner. 4. Ongoing Monitoring: the health center will establish monthly internal audits of sliding fee discount determinations to monitor compliance. Audit results will be documented and reviewed by management to ensure corrective actions are taken as needed. Responsible Party: Chief Financial Officer Target Completion Date: 04/30/2026 If the Cognizant or Oversight Agency for Audit has questions regarding this plan, please call: Javier Vallejo, CFO at (314)-482-0915. Sincerely yours, Javier Vallejo Chief Financial Officer

Categories

Internal Control / Segregation of Duties Special Tests & Provisions Subrecipient Monitoring Allowable Costs / Cost Principles Eligibility HUD Housing Programs Significant Deficiency

Other Findings in this Audit

  • 1169206 2025-002
    Material Weakness Repeat
  • 1169207 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) $6.18M
10.557 WIC SPECIAL SUPPLEMENTAL NUTRITION PROGRAM FOR WOMEN, INFANTS, AND CHILDREN $684,923
93.526 GRANTS FOR CAPITAL DEVELOPMENT IN HEALTH CENTERS $324,264
93.778 MEDICAL ASSISTANCE PROGRAM $292,924
93.332 COOPERATIVE AGREEMENT TO SUPPORT NAVIGATORS IN FEDERALLY-FACILITATED EXCHANGES $120,149
21.027 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $110,517
93.323 EPIDEMIOLOGY AND LABORATORY CAPACITY FOR INFECTIOUS DISEASES (ELC) $62,095
93.898 CANCER PREVENTION AND CONTROL PROGRAMS FOR STATE, TERRITORIAL AND TRIBAL ORGANIZATIONS $14,655
93.600 HEAD START $3,858
93.527 GRANTS FOR NEW AND EXPANDED SERVICES UNDER THE HEALTH CENTER PROGRAM $3,328