Finding Text
Finding Number 2024-005 – Ineffective Internal Controls over Sliding Fee Revenues Federal Program Name Health Center Program Project NO. H80CS00680-21-00, H80CS00680-22-00 CFDA # 93.224/93.527 Federal Agency Department of Health and Human Services Criteria The Corporation is responsible for establishing and maintaining an internal control system over sliding fee and clinic service eligibility requirements. Specifically, health centers must prepare and apply a sliding fee discount schedule (SFDS) so that the amounts owed for health center services by eligible patients are adjusted (discounted) based on the patient’s ability to pay as follows: • Sliding fee discounts are applied to fees for health center services provided to all individuals and families with annual incomes at or below 200 percent of the Federal Poverty Guidelines (FPG); • A full discount is applied to fees for health center services provided to individuals and families with annual incomes at or below 100 percent of the FPG, or the health center applies only a nominal charge; • Fees for health center services are discounted based on graduations in family size and income for individuals and families with incomes above 100 and at or below 200 percent of the FPG; and • No sliding fee discount is applied to fees for health center services provided to individuals and families within 200 percent or more of the FPG. Condition During the compliance testing of the Uniform Guidance “Special Tests and Provisions – Sliding Fee Applications” requirements, we noted the following exception: • One (1) out of thirteen (13) sampled had an expired application but the system continued to apply the slide fee discount. Questioned Costs: Not applicable. Context The population of patients receiving slide adjustments is approximately 75 patients, 130 encounters and gross charges of approximately $17,000. The sample size represented 13 encounters $2,455 in charges of which 1 encounter ($102 in charges) was found to have compliance issues noted above. Cause The billing system continues to apply the discount until manually changed. The staff missed removing the discount when a new application was not provided by the patient. Effect Lack of effective internal control procedures could result in unintentional or intentional errors that may not be detected in a timely manner by employees in the normal course of performing their assigned duties. Recommendation Management should take steps to ensure procedures over sliding fee applications are properly designed and operating effectively. Management’s Response Management agrees with the finding. The charge in the system outlined above had not yet been paid so management removed the slide discount to show full charges due by the patient.