FAC Explorer

Finding 1204902 (2025-006)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2025
Accepted
2026-03-30
Audit: 396507
Organization: County of Ventura (CA)
Auditor: EIDE BAILLY LLP

AI Summary

  • Core Issue: The County failed to apply sliding fee discounts correctly for patient charges, affecting compliance with federal requirements.
  • Impacted Requirements: Internal controls over compliance as per 2 CFR section 200.303(a) and sliding fee discount provisions under Title 42 USC 254b(k)(3)(F).
  • Recommended Follow-Up: Strengthen policies and procedures to ensure proper application of sliding fee discounts and ensure thorough documentation and review by County personnel.

Finding Text

Program: Health Center Program Cluster Assistance Listing No.: 93.224 Federal Grantor: U.S. Department of Health and Human Services Passed-through: N/A Award No.: 5 H80CS00247-22-00 Award Year: 2024 Compliance Requirement: Special Tests and Provisions - Sliding Fee Discounts Type of Finding: Material Weakness in Internal Control over Compliance and Material Non-Compliance Criteria: 2 CFR section 200.303(a), Internal Controls, states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Per Title 42 USC 254b(k)(3)(F), the Center has made or will make and will continue to make every reasonable effort to collect appropriate reimbursement for its costs in providing health services to persons who are entitled to insurance benefits under title XVIII of the Social Security Act [42 U.S.C. 1395 et seq.], to medical assistance under a State plan approved under title XIX of such Act [42 U.S.C. 1396 et seq.], or to assistance for medical expenses under any other public assistance program or private health insurance program; (G) the center—(i) has prepared a schedule of fees or payments for the provision of its services consistent with locally prevailing rates or charges and designed to cover its reasonable costs of operation and has prepared a corresponding schedule of discounts to be applied to the payment of such fees or payments, which discounts are adjusted on the basis of the patient’s ability to pay; (ii) has made and will continue to make every reasonable effort—(I) to secure from patients payment for services in accordance with such schedules. Condition: We noted three (3) out of sixty (60) where the County did not appropriately adjust patient charges based on the Health Center’s sliding fee discount program schedules in accordance with 42 USC 254b(k)(3)(F). We also noted there was no review of the sliding fee discount by the County for two (2) out of sixty (60) sliding fee samples. Cause: The condition is primarily caused by the County not following the policies and procedures in place to ensure the sliding fee discounts to patient charges were applied consistent with its sliding fee discount program schedules. Effect: Discounts applied to patient charges were inconsistent with its sliding fee discount program schedules. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of sixty (60) out of three thousand seven hundred forty-eight (3,748) participants were tested. Repeat Finding from Prior Years: No. Recommendation: We recommend that the County strengthen its established policies and procedures to ensure the sliding fee discount program schedules are applied to patient charges consistent with its sliding fee discount schedules, ensure that policies and procedures are strictly adhered to by County personnel and the County’s review is performed and documented. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.

Corrective Action Plan

Program: Health Center Program Cluster Assistance Listing No.: 93.224 Federal Grantor: U.S. Department of Health and Human Services Passed-through: N/A Award No.: 5 H80CS00247-22-00 Award Year: 2024 Compliance Requirement: Special Tests and Provisions - Sliding Fee Discounts Type of Finding: Material Weakness in Internal Control over Compliance and Material Non-Compliance Department’s Management Response: Health Care Agency (HCA) management agrees and acknowledges the findings related to the application and review of sliding fee discounts under the Self-Pay Discount Program. The Department recognizes the importance of consistent application of sliding fee discount schedules and proper documentation of review processes to ensure full compliance with federal requirements. The Department is committed to maintaining strong internal controls and ensuring adherence to all applicable policies, procedures, and regulatory standards governing the Sliding Fee Discount Program. View of Responsible Officials and Corrective Action: HCA Management agrees with the finding and will implement corrective actions to strengthen internal controls and ensure consistent application of the sliding fee discount program. The following actions will be taken: • Reinforcement of Policies and Procedures: Re-educate all applicable staff on existing sliding fee discount program policies, including proper calculation and application of discounts. First re-education session was held on February 4, 2026. • Standardization of Workflow: Update and implement standardized workflows and job aids within the registration and billing processes to ensure discounts are applied accurately and consistently. Standardized workflows completed on February 2, 2026. • Enhanced Review and Oversight: Establish a formalized secondary review process for sliding fee discount determinations, including required documentation and supervisory sign-off. Supervisor sign off on sliding fee applications by April 1, 2026. • Ongoing Training: Incorporate sliding fee discount program requirements into onboarding and annual refresher training for relevant staff beginning April 1, 2026. • Audit and Monitoring: Conduct monthly internal audits of sliding fee discount applications to monitor compliance and identify any trends or gap by May 1, 2026. These corrective actions are designed to ensure compliance with federal requirements, improve consistency in application, and strengthen overall internal controls. Name of Responsible Persons: Octavius Gonzaga, Ambulatory Care CFO – Establishes sliding fee discount program policy, procedures, and fee schedules. Erika Herincx, Ambulatory Care Revenue Cycle Manager – Responsible for the oversight of the training program and ensures the listed activities in the Corrective Action Plan are executed. Implementation Date: February 4 - March 30, 2026 – Training of front-end staff and clinic management. April 1, 2026 – Implementation of supervisor sign off for each sliding fee application. April 1, 2026 – Re-Training of Medical Billing Specialists on adjustments. May 1, 2026 – Monthly sampling of encounters December 1, 2026 – Year-to-date report and internal audit

Categories

Special Tests & Provisions Cash Management Material Weakness Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties

Other Findings in this Audit

  • 1204880 2025-001
    Material Weakness Repeat
  • 1204881 2025-002
    Material Weakness Repeat
  • 1204882 2025-001
    Material Weakness Repeat
  • 1204883 2025-002
    Material Weakness Repeat
  • 1204884 2025-003
    Material Weakness Repeat
  • 1204885 2025-003
    Material Weakness Repeat
  • 1204886 2025-003
    Material Weakness Repeat
  • 1204887 2025-003
    Material Weakness Repeat
  • 1204888 2025-003
    Material Weakness Repeat
  • 1204889 2025-003
    Material Weakness Repeat
  • 1204890 2025-003
    Material Weakness Repeat
  • 1204891 2025-004
    Material Weakness Repeat
  • 1204892 2025-004
    Material Weakness Repeat
  • 1204893 2025-004
    Material Weakness Repeat
  • 1204894 2025-004
    Material Weakness Repeat
  • 1204895 2025-004
    Material Weakness Repeat
  • 1204896 2025-004
    Material Weakness Repeat
  • 1204897 2025-004
    Material Weakness Repeat
  • 1204898 2025-005
    Material Weakness Repeat
  • 1204899 2025-005
    Material Weakness Repeat
  • 1204900 2025-005
    Material Weakness Repeat
  • 1204901 2025-006
    Material Weakness Repeat
  • 1204903 2025-007
    Material Weakness Repeat
  • 1204904 2025-008
    Material Weakness Repeat
  • 1204905 2025-009
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
93.563 CHILD SUPPORT SERVICES $14.73M
10.557 WIC SPECIAL SUPPLEMENTAL NUTRITION PROGRAM FOR WOMEN, INFANTS, AND CHILDREN $4.55M
93.323 COVID-19 - EPIDEMIOLOGY AND LABORATORY CAPACITY FOR INFECTIOUS DISEASES (ELC) $4.14M
93.090 GUARDIANSHIP ASSISTANCE $2.48M
93.045 SPECIAL PROGRAMS FOR THE AGING, TITLE III, PART C, NUTRITION SERVICES $2.36M
97.047 BRIC: BUILDING RESILIENT INFRASTRUCTURE AND COMMUNITIES $1.70M
93.268 COVID-19 - IMMUNIZATION COOPERATIVE AGREEMENTS $1.64M
10.923 EMERGENCY WATERSHED PROTECTION PROGRAM $1.39M
16.738 EDWARD BYRNE MEMORIAL JUSTICE ASSISTANCE GRANT PROGRAM $1.38M
16.833 NATIONAL SEXUAL ASSAULT KIT INITIATIVE $1.06M
93.958 BLOCK GRANTS FOR COMMUNITY MENTAL HEALTH SERVICES $809,291
20.205 HIGHWAY PLANNING AND CONSTRUCTION $733,656
93.044 SPECIAL PROGRAMS FOR THE AGING, TITLE III, PART B, GRANTS FOR SUPPORTIVE SERVICES AND SENIOR CENTERS $634,949
93.659 ADOPTION ASSISTANCE $614,153
93.667 SOCIAL SERVICES BLOCK GRANT $595,460
14.218 COVID-19 - COMMUNITY DEVELOPMENT BLOCK GRANTS/ENTITLEMENT GRANTS $574,506
16.606 STATE CRIMINAL ALIEN ASSISTANCE PROGRAM $572,769
93.556 MARYLEE ALLEN PROMOTING SAFE AND STABLE FAMILIES PROGRAM $566,995
16.838 COMPREHENSIVE OPIOID, STIMULANT, AND OTHER SUBSTANCES USE PROGRAM $536,576
93.917 HIV CARE FORMULA GRANTS $509,192
14.241 HOUSING OPPORTUNITIES FOR PERSONS WITH AIDS $502,368
93.994 MATERNAL AND CHILD HEALTH SERVICES BLOCK GRANT TO THE STATES $452,925
93.959 BLOCK GRANTS FOR PREVENTION AND TREATMENT OF SUBSTANCE ABUSE $447,971
14.912 LEAD HAZARD CONTROL CAPACITY BUILDING $433,373
93.052 NATIONAL FAMILY CAREGIVER SUPPORT, TITLE III, PART E $420,391
14.267 CONTINUUM OF CARE PROGRAM $402,632
93.658 FOSTER CARE TITLE IV-E $380,427
14.920 LEAD HAZARD CONTROL FOR HIGH RISK AREAS $376,491
84.126 REHABILITATION SERVICES VOCATIONAL REHABILITATION GRANTS TO STATES $371,125
93.645 STEPHANIE TUBBS JONES CHILD WELFARE SERVICES PROGRAM $355,675
93.558 TEMPORARY ASSISTANCE FOR NEEDY FAMILIES $351,467
17.259 WIOA YOUTH ACTIVITIES $345,204
93.526 COVID-19 - GRANTS FOR CAPITAL DEVELOPMENT IN HEALTH CENTERS $338,663
16.922 EQUITABLE SHARING PROGRAM $338,311
17.270 REENTRY EMPLOYMENT OPPORTUNITIES $331,324
16.812 SECOND CHANCE ACT REENTRY INITIATIVE $323,827
93.889 NATIONAL BIOTERRORISM HOSPITAL PREPAREDNESS PROGRAM $303,668
17.278 WIOA DISLOCATED WORKER FORMULA GRANTS $299,949
93.224 HEALTH CENTER PROGRAM (COMMUNITY HEALTH CENTERS, MIGRANT HEALTH CENTERS, HEALTH CARE FOR THE HOMELESS, AND PUBLIC HOUSING PRIMARY CARE) $295,987
66.046 CLIMATE POLLUTION REDUCTION GRANTS $285,875
93.354 COVID-19 - PUBLIC HEALTH EMERGENCY RESPONSE: COOPERATIVE AGREEMENT FOR EMERGENCY RESPONSE: PUBLIC HEALTH CRISIS RESPONSE $272,927
93.778 MEDICAL ASSISTANCE PROGRAM $265,651
14.228 COMMUNITY DEVELOPMENT BLOCK GRANTS/STATE'S PROGRAM AND NON-ENTITLEMENT GRANTS IN HAWAII $251,968
97.036 COVID-19 - DISASTER GRANTS - PUBLIC ASSISTANCE (PRESIDENTIALLY DECLARED DISASTERS) $243,609
93.472 TITLE IV-E PREVENTION PROGRAM $228,910
16.320 ACADEMIC-BASED DRUG FIELD TESTING AND TRAINING INITIATIVE $227,516
97.067 HOMELAND SECURITY GRANT PROGRAM $222,522
93.918 GRANTS TO PROVIDE OUTPATIENT EARLY INTERVENTION SERVICES WITH RESPECT TO HIV DISEASE $211,246
10.561 STATE ADMINISTRATIVE MATCHING GRANTS FOR THE SUPPLEMENTAL NUTRITION ASSISTANCE PROGRAM $176,830
97.042 EMERGENCY MANAGEMENT PERFORMANCE GRANTS $175,850
93.268 IMMUNIZATION COOPERATIVE AGREEMENTS $165,572
93.053 NUTRITION SERVICES INCENTIVE PROGRAM $165,393
93.674 JOHN H. CHAFEE FOSTER CARE PROGRAM FOR SUCCESSFUL TRANSITION TO ADULTHOOD $149,412
17.258 WIOA ADULT PROGRAM $142,341
20.106 AIRPORT IMPROVEMENT PROGRAM, INFRASTRUCTURE INVESTMENT AND JOBS ACT PROGRAMS, AND COVID-19 AIRPORTS PROGRAMS $136,214
93.967 CENTERS FOR DISEASE CONTROL AND PREVENTION COLLABORATION WITH ACADEMIA TO STRENGTHEN PUBLIC HEALTH $131,320
14.239 HOME INVESTMENT PARTNERSHIPS PROGRAM $122,131
93.470 SPECIAL PROGRAMS FOR THE AGING, TITLE VI, PART A, GRANTS TO INDIAN TRIBES, PART B, GRANTS TO NATIVE HAWAIIANS $121,542
93.391 ACTIVITIES TO SUPPORT STATE, TRIBAL, LOCAL AND TERRITORIAL (STLT) HEALTH DEPARTMENT RESPONSE TO PUBLIC HEALTH OR HEALTHCARE CRISES $117,457
93.150 HIV PREVENTION PROGRAMS FOR WOMEN $115,598
20.608 MINIMUM PENALTIES FOR REPEAT OFFENDERS FOR DRIVING WHILE INTOXICATED $109,105
93.977 SEXUALLY TRANSMITTED DISEASES (STD) PREVENTION AND CONTROL GRANTS $108,646
93.071 MEDICARE ENROLLMENT ASSISTANCE PROGRAM $97,059
20.616 NATIONAL PRIORITY SAFETY PROGRAMS $91,717
93.116 PROJECT GRANTS AND COOPERATIVE AGREEMENTS FOR TUBERCULOSIS CONTROL PROGRAMS $90,732
93.566 REFUGEE AND ENTRANT ASSISTANCE STATE/REPLACEMENT DESIGNEE ADMINISTERED PROGRAMS $85,722
20.507 FEDERAL TRANSIT FORMULA GRANTS $85,665
20.600 STATE ACCESS TO THE OIL SPILL LIABILITY TRUST FUND $84,288
14.231 EMERGENCY SOLUTIONS GRANT PROGRAM $83,650
97.152 REHABILITATION OF HIGH HAZARD POTENTIAL DAMS GRANT PROGRAM $81,646
93.324 STATE HEALTH INSURANCE ASSISTANCE PROGRAM $81,135
93.043 SPECIAL PROGRAMS FOR THE AGING, TITLE III, PART D, DISEASE PREVENTION AND HEALTH PROMOTION SERVICES $70,541
10.704 LAW ENFORCEMENT AGREEMENTS $70,499
21.009 VOLUNTEER INCOME TAX ASSISTANCE (VITA) MATCHING GRANT PROGRAM $58,871
93.042 SPECIAL PROGRAMS FOR THE AGING, TITLE VII, CHAPTER 2, LONG TERM CARE OMBUDSMAN SERVICES FOR OLDER INDIVIDUALS $58,553
16.753 CONGRESSIONALLY RECOMMENDED AWARDS $58,400
16.575 CRIME VICTIM ASSISTANCE $57,662
10.665 SCHOOLS AND ROADS - GRANTS TO STATES $50,635
16.U01 ERADICATION SUPPRESSION FY 2024 DEA DOMESTIC CANNABIS ERADICATION SUPPRESSION PROGRAM $50,000
16.741 DNA BACKLOG REDUCTION PROGRAM $49,318
93.069 PUBLIC HEALTH EMERGENCY PREPAREDNESS $44,882
17.277 WIOA NATIONAL DISLOCATED WORKER GRANTS / WIA NATIONAL EMERGENCY GRANTS $35,321
10.693 WATERSHED RESTORATION AND ENHANCEMENT AGREEMENT AUTHORITY $35,000
16.036 COMPREHENSIVE FORENSIC DNA ANALYSIS GRANT PROGRAM $34,512
14.218 COMMUNITY DEVELOPMENT BLOCK GRANTS/ENTITLEMENT GRANTS $33,884
97.044 ASSISTANCE TO FIREFIGHTERS GRANT $30,927
97.039 HAZARD MITIGATION GRANT $27,412
97.036 DISASTER GRANTS - PUBLIC ASSISTANCE (PRESIDENTIALLY DECLARED DISASTERS) $25,392
10.025 PLANT AND ANIMAL DISEASE, PEST CONTROL, AND ANIMAL CARE $24,183
15.664 FISH AND WILDLIFE COORDINATION AND ASSISTANCE $20,000
16.U01 ERADICATION SUPPRESSION FY 2025 DEA DOMESTIC CANNABIS ERADICATION SUPPRESSION PROGRAM $16,838
16.742 PAUL COVERDELL FORENSIC SCIENCES IMPROVEMENT GRANT PROGRAM $12,674
93.041 SPECIAL PROGRAMS FOR THE AGING, TITLE VII, CHAPTER 3, PROGRAMS FOR PREVENTION OF ELDER ABUSE, NEGLECT, AND EXPLOITATION $10,384
16.710 PUBLIC SAFETY PARTNERSHIP AND COMMUNITY POLICING GRANTS $9,429
17.235 SENIOR COMMUNITY SERVICE EMPLOYMENT PROGRAM $8,602
93.008 MEDICAL RESERVE CORPS SMALL GRANT PROGRAM $5,582
90.404 HAVA ELECTION SECURITY GRANTS $2,516
45.310 AMERICAN LATINO MUSEUM INTERNSHIP AND FELLOWSHIP INITIATIVE $500