Finding Text
Finding Number: 2025 001 Finding Type: Significant Deficiency in Internal Controls Over Compliance related to Special Tests and Provisions Information on the Federal Program: Program Name: Health Center Program Cluster (AL numbers 93.224 and 93.527) Grant Award: 5 H80CS00881-22 from May 1, 2024 through April 30, 2025 and 5 H80CS00881-23 from May 1, 2025 through April 30, 2026 Agency: U.S. Department of Health and Human Services, Health Resources and Services Administration Pass-Through Entity: N/A Criteria: In accordance with Section 330(k)(3)(G) of the Public Health Services Act (42 U.S. Code § 254b), as an FQHC, the Organization must have a sliding fee discount program in which patient charges are adjusted based on the patient’s ability to pay. Condition: Through testing a statistically valid sample of 25 individual patient balances, we noted one instance in which the sliding fee discount applied was inconsistent with the Organization’s policy. Based on income and family size, the patient received a discount of $262 but qualified for a discount of $302, resulting in a $40 difference. Cause: The billing system was not properly configured to ensure all eligible services were included within the sliding fee discount logic. In addition, the Organization does not currently have a formal monitoring process or policy to ensure discounts are applied correctly to patient balances, which increases the risk that errors may occur and go undetected. Effect: It is possible that sliding fee discounts may not be applied consistently across all patient accounts, and errors may not be identified and corrected in a timely manner, which could result in noncompliance with the Organization’s sliding fee discount program and federal program requirements. Questioned Costs: None Repeat Finding: No Recommendation: The Organization should establish a formal procedure to monitor compliance with its sliding fee discount program. The procedure should assign responsibility for reviewing applied discounts, define the frequency and sample size of reviews, and include consideration for differences between the Medical and Dental systems, with a larger or more frequent sample for Dental due to higher manual processing and volume. The procedure should also include steps to document and correct any errors identified and require supervisory oversight to verify that reviews are performed consistently. Implementing this procedure will help ensure discounts are applied accurately and in accordance with the Organization’s policy and federal requirements. Views of a Responsible Official and Corrective Action Plan: Management agrees with the finding and will develop and implement the recommendations above.