Finding 1173608 (2025-002)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2025
Accepted
2026-02-16
Audit: 387331
Organization: Total Health Care, Inc. (MD)

AI Summary

  • Core Issue: Patients received sliding fee discounts that did not match the organization's policy categories.
  • Impacted Requirements: Compliance with sliding fee discount regulations (42 USC 254(k)(3)(G); 42 CFR sections 51c.303(g) and 56.303(f)).
  • Recommended Follow-Up: Enhance training for staff on the sliding fee scale policy and implement procedures to ensure discounts align with the policy and compliance manual.

Finding Text

Health Center Program Cluster Assistance Listing Numbers 93.224 and 93.527 U.S. Department of Health and Human Services Health Center Program Cluster Assistance Listing Numbers 93.224 and 93.527 U.S. Department of Health and Human Services Criteria or specific requirement – Special Tests and Provisions: Sliding Fee Discounts (42 USC 254(k)(3)(G); 42 CFR sections 51c.303(g); and 42 CFR sections 56.303 (f)) Condition – Patients received a sliding fee discount that was inconsistent with the stated sliding fee discount categories under the Organization’s policy. Cause – The Organization did not comply with their sliding fee policy Questioned Cost – None Effect or Potential Effect – Sliding fee discounts recorded were inconsistent with the Organization’s sliding fee discount policy. Context – A sample of 40 encounters were tested out of the total population of 98,273 encounters. The sampling methodology used is not and is not intended to be statistically valid. Two patients received a sliding fee adjustment that was inconsistent with the approved policy for the proper sliding fee adjustments based on their income and family size documentation. Identification as a Repeat Finding, if Applicable – Yes, see finding 2024-002. Recommendation – We recommend management continue to train personnel and ensure all personnel understand the sliding fee scale policy and adhere to the requirements and guidelines set forth in the policy. Procedures should be implemented to ensure that eligible patients receive discounts in accordance with the sliding fee scale and the Health Center Program Compliance Manual.

Corrective Action Plan

Views of Responsible Officials and Planned Corrective Actions – Total Health Care will conduct regular testing of its application process for the sliding fee discount. This will include reviews of the documents and support provided by applicants for the sliding fee. These reviews will be conducted randomly throughout the year and will be based on sample selections. Total Health Care is committed to insuring that every applicant who is eligible for its sliding fee discount is accurately identified, and the sliding fee benefit is correctly awarded. These steps will also include random and unannounced observation and inspection of the sliding fee process. Organization Contact Person Responsible for Corrective Action – Richard Greene, CFO Anticipated completion date: 6/30/26

Categories

Special Tests & Provisions

Other Findings in this Audit

  • 1173606 2025-002
    Material Weakness Repeat
  • 1173607 2025-002
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
93.224 Health Center Program $8.42M
93.527 GRANTS FOR NEW AND EXPANDED SERVICES UNDER THE HEALTH CENTER PROGRAM $721,150
93.914 HIV EMERGENCY RELIEF PROJECT GRANTS $591,069
93.918 GRANTS TO PROVIDE OUTPATIENT EARLY INTERVENTION SERVICES WITH RESPECT TO HIV DISEASE $496,420
93.247 ADVANCED NURSING EDUCATION WORKFORCE GRANT PROGRAM $140,554
93.527 COVID-19 Health Center Program $22,049
93.940 HIV PREVENTION ACTIVITIES HEALTH DEPARTMENT BASED $6,954