Finding 1213508 (2025-003)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2025
Accepted
2026-05-01
Audit: 400452
Organization: Seattle Indian Health Board (WA)

AI Summary

  • Core Issue: The Health Board failed to maintain necessary data to support the sliding fee discount program, leading to potential billing inaccuracies for eligible patients.
  • Impacted Requirements: Compliance with the Health Center Program Compliance Manual and internal policies regarding the sliding fee discount schedule was not met.
  • Recommended Follow-Up: Implement additional processes and training to ensure accurate application of the sliding fee scale for all qualifying patients.

Finding Text

Finding 2025-003 – Special Tests and Provisions (Material Weakness in Internal Control Over Compliance) Criteria – In accordance with the Health and Resources & Services Administration Health Center Program Compliance Manual, Chapter 9: Sliding Fee Discount Program, health centers must prepare and apply a sliding fee discount scheduled so that amounts owed for health center services by eligible patients are adjusted based on the patients’ ability to pay. Condition and Context – We selected 40 patient visits out of the entire population of patients who may be eligible to receive benefits under the program during the fiscal year ended September 30, 2025. The Health Board did not retain underlying data in accordance with policy to support the sliding fee scale discount based on the patients’ family size or income. Additionally, the Health Board had instances in which discounts were not applied accurately based on the underlying support that was provided by the patient. In 6 out of the 40 samples tested, the Health Board was unable to locate underlying support required per their policy. Cause – The program did not follow the Health Board’s established policies to appropriately apply the sliding fee discounts under Uniform Guidance. Effect – Certain patients may have been billed amounts less than the amounts defined by the sliding fee discount schedule. Questioned Costs – Not applicable. Repeat Finding – This is not a repeat finding. Recommendation – We recommend that further processes and training be put in place to ensure that the sliding fee scale is accurately applied to all qualifying program participants. Views of responsible officials – Management agrees with the auditors’ findings and will implement the corrective action plan to address the issue identified.

Corrective Action Plan

Finding 2025-003 – Special Tests and Provisions (Material Weakness in Internal Control Over Compliance) Planned Corrective Action: Seattle Indian Health Board will implement the following actions to ensure accurate application and documentation of the Sliding Fee Discount Program: - EPIC System Update: Configure EPIC to automatically assign the appropriate sliding fee discount level to patients with zero income to ensure consistent application of the discount schedule. - Required Income Documentation at Intake: Update procedures to require front desk staff to record a patient’s income level at intake for all patients, including a reasonable estimate when documentation in unavailable. This is required for both an accurate sliding fee application and UDS reporting. - Standardized Documentation Requirements: Require retention of supporting documentation for income and family size in the patient record, or documented attestation when estimates are used, in accordance with policy. - Front Desk Training and Accountability: Provide targeted training to front desk and registration staff on sliding fee discount program requirements, with emphasis on proper data entry, documentation standards, and discount application. - Ongoing Monitoring: Implement monthly reviews of a sample of patient accounts to confirm sliding fee discounts are supported, accurately applied, and properly documented. Errors will be corrected and addressed with the staff as needed. Name of Responsible Party: Tempest Dawson, Director of Clinic Operations Anticipated Completion Date: December 31, 2026.

Categories

Special Tests & Provisions Material Weakness Internal Control / Segregation of Duties

Other Findings in this Audit

  • 1213497 2025-001
    Material Weakness Repeat
  • 1213498 2025-002
    Material Weakness Repeat
  • 1213499 2025-001
    Material Weakness Repeat
  • 1213500 2025-002
    Material Weakness Repeat
  • 1213501 2025-001
    Material Weakness Repeat
  • 1213502 2025-002
    Material Weakness Repeat
  • 1213503 2025-001
    Material Weakness Repeat
  • 1213504 2025-002
    Material Weakness Repeat
  • 1213505 2025-003
    Material Weakness Repeat
  • 1213506 2025-003
    Material Weakness Repeat
  • 1213507 2025-003
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
93.231 EPIDEMIOLOGY PROGRAM $4.77M
93.527 GRANTS FOR NEW AND EXPANDED SERVICES UNDER THE HEALTH CENTER PROGRAM $1.44M
93.323 EPIDEMIOLOGY AND LABORATORY CAPACITY FOR INFECTIOUS DISEASES (ELC) $1.39M
93.479 GOOD HEALTH AND WELLNESS IN INDIAN COUNTRY $1.25M
93.762 A COMPREHENSIVE APPROACH TO GOOD HEALTH AND WELLNESS IN INDIAN COUNTY – FINANCED SOLELY BY PREVENTION AND PUBLIC HEALTH $1.03M
93.193 URBAN INDIAN HEALTH SERVICES $729,183
93.237 SPECIAL DIABETES PROGRAM FOR INDIANS DIABETES PREVENTION AND TREATMENT PROJECTS $446,870
93.224 HEALTH CENTER PROGRAM (COMMUNITY HEALTH CENTERS, MIGRANT HEALTH CENTERS, HEALTH CARE FOR THE HOMELESS, AND PUBLIC HOUSING PRIMARY CARE) $408,298
93.073 BIRTH DEFECTS AND DEVELOPMENTAL DISABILITIES - PREVENTION AND SURVEILLANCE $315,103
93.243 SUBSTANCE ABUSE AND MENTAL HEALTH SERVICES PROJECTS OF REGIONAL AND NATIONAL SIGNIFICANCE $205,712
93.933 DEMONSTRATION PROJECTS FOR INDIAN HEALTH $177,556
93.441 INDIAN SELF-DETERMINATION $175,214
16.023 SEXUAL ASSAULT SERVICES CULTURALLY SPECIFIC PROGRAM $133,514
10.557 WIC SPECIAL SUPPLEMENTAL NUTRITION PROGRAM FOR WOMEN, INFANTS, AND CHILDREN $110,500
93.654 INDIAN HEALTH SERVICE BEHAVIORAL HEALTH PROGRAMS $83,439
93.788 OPIOID STR $72,952