Finding 1173794 (2023-002)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2023
Accepted
2026-02-16
Audit: 387440

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 policies as outlined in federal regulations (42 USC 254 and 42 CFR sections 51c.303 and 56.303).
  • Recommended Follow-Up: Ensure all staff understand and follow the sliding fee scale policy; implement procedures for consistent application of discounts.

Finding Text

Health Center Program Assistance Listing Numbers 93.224 and 93.527 U.S. Department of Health and Human Services Award No. 6 H80CS00188-22-07 Program Year 2023 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. Effect or potential effect – Sliding fee discounts were given to patients that were inconsistent with the Organization’s sliding fee discount policy. Questioned Cost – None Context - A sample of 25 encounters out of the total population of 389,021 encounters. The sampling methodology used is not and is not intended to be statistically valid. Four patients received a sliding fee adjustment that was inconsistent with the approved policy based on their income documentation Identification as a repeat finding – Not a repeat finding Recommendation – We recommend management continue to 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

We agree with the findings as stated for the four encounters reviewed. The corrective action plan follows. 1. Person responsible for the corrective action: Terry Terry, Chief Financial Officer 2. Corrective Action: a. Sliding Fee procedures will be reviewed quarterly during training calls with Patient Service Representatives with emphasis on proper income documentation. b. Any deficiencies identified during performance audits are communicated to the staff members’ direct supervisor who reviews the errors with the staff member. There will be an acknowledgement of understanding of the error or a request for additional one-on-one training by Amye Groue, EPM auditor and trainer. c. After initial training, Ms. Groue does a check-in after the first two weeks to ask if there are any questions that have come up for which additional training is needed. An audit of ten encounters is performed after the first ninety days to identify any training deficits and revisit the policies as needed. 3. The Corrective Actions for performance audits and initial training were implemented in 2025. The documented acknowledgement of the audit findings review will be implemented in March 2026. The quarterly focused training for Sliding Fee income documentation will begin with the March 2026 session, which is held on the third Wednesday of each month.

Categories

Special Tests & Provisions

Other Findings in this Audit

  • 1173791 2023-002
    Material Weakness Repeat
  • 1173792 2023-002
    Material Weakness Repeat
  • 1173793 2023-002
    Material Weakness Repeat
  • 1173795 2023-003
    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) $2.17M
93.498 PROVIDER RELIEF FUND AND AMERICAN RESCUE PLAN (ARP) RURAL DISTRIBUTION $1.46M
93.918 GRANTS TO PROVIDE OUTPATIENT EARLY INTERVENTION SERVICES WITH RESPECT TO HIV DISEASE $549,042
93.527 GRANTS FOR NEW AND EXPANDED SERVICES UNDER THE HEALTH CENTER PROGRAM $372,391
10.557 WIC SPECIAL SUPPLEMENTAL NUTRITION PROGRAM FOR WOMEN, INFANTS, AND CHILDREN $278,273
93.137 COMMUNITY PROGRAMS TO IMPROVE MINORITY HEALTH $120,000
93.738 PPHF: RACIAL AND ETHNIC APPROACHES TO COMMUNITY HEALTH PROGRAM FINANCED SOLELY BY PUBLIC PREVENTION AND HEALTH FUNDS $62,507
93.592 FAMILY VIOLENCE PREVENTION AND SERVICES/DISCRETIONARY $56,750
93.359 NURSE EDUCATION, PRACTICE QUALITY AND RETENTION GRANTS $29,941
93.837 CARDIOVASCULAR DISEASES RESEARCH $21,040
93.426 THE NATIONAL CARDIOVASCULAR HEALTH PROGRAM $17,760
93.136 INJURY PREVENTION AND CONTROL RESEARCH AND STATE AND COMMUNITY BASED PROGRAMS $13,560
93.378 INTEGRATED CARE FOR KIDS MODEL $13,420
14.218 COMMUNITY DEVELOPMENT BLOCK GRANTS/ENTITLEMENT GRANTS $5,125