Finding Text
Finding 2025-001 – Special Tests and Provisions – Significant Deficiency in Internal Control over Compliance Federal Program: U.S. Department of Health and Human Services Health Center Program Cluster (Federal Assistance Listing # 93.224/93.527) Federal Agency: U.S. Department of Health and Human Services Award Year: 2024-2025 Criteria: The recipient is required to comply with specific federal regulations and provisions outlined in 2 CFR Part 200, particularly those related to special tests and provisions for the Health Center Program Cluster. This includes maintaining an effective internal control environment to ensure sliding fee discounts are applied to patient charges consistent with the recipients sliding fee discount schedule. Condition/Cause: During the audit, it was identified that LifeLong did not retain underlying data in accordance with policy to support the sliding fee scale discount based on the patients’ family size or income. It was also identified that LifeLong did not properly apply the sliding fee scale discount in accordance with sliding scale policy based on the patients’ family size or income. There were several turnovers in the department which resulted in inconsistent application of the sliding scale policies and insufficient staff training on eligibility determination and documentation requirements. Potential effect: Certain patients may have been billed amounts in excess of and less than the amounts defined by the sliding fee discount schedule. Questioned costs: Not applicable. Context: We selected a sample of 40 patient visits from a statistically valid population of patients potentially eligible for benefits under the sliding fee schedule during the fiscal year ended June 30, 2025. In 2 out of 40 samples tested, LifeLong was unable to locate underlying support required per their policy. In 2 out of 40 samples tested, LifeLong did not properly apply the sliding fee scale discount based on the patients’ family size or income. Repeat Finding: This is a repeat finding. Recommendation: We recommend implementing stronger controls to ensure proper documentation and accuracy of sliding fee discounts. Specifically, the organization should ensure that proof of income is collected and saved before applying any discounts. Additionally, checks should be added to the Electronic Medical Record (EMR) or intake process to prevent discounts from being applied unless required income information is on file. A quick supervisor review should also be implemented, particularly for new patients or those with updated income information, to confirm that income documents match what is entered into the EMR before billing is finalized. These measures will enhance compliance and reduce the risk of errors in the discount process. Views of responsible officials: LifeLong concurs with the finding. LifeLong is working on retraining staff involved in Sliding Fee Discount Program (SFDP) and training all new staff at new hire orientations. In the future, LifeLong will perform periodic audits of sliding fee transactions.