Finding 1214652 (2025-001)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2025
Accepted
2026-05-14
Audit: 401373
Auditor: CHW LLP

AI Summary

  • Core Issue: Three patients received incorrect sliding fee discounts due to miscalculations based on family size and income.
  • Impacted Requirements: Compliance with federal grant provisions for accurately determining patient discounts under the sliding fee schedule.
  • Recommended Follow-Up: Provide employee training on sliding fee requirements and conduct regular audits of transactions to ensure compliance.

Finding Text

2025-001 Sliding Fee Discount Determination ALN: 93.224 Program: Community Health Center Cluster Agency: US Department of Health and Human Services Compliance Requirement: N Special Tests and Provisions Repeat Finding: No Criteria: Federal grant compliance provisions require that the Center correctly identify a patient's ability to pay and that the rates for services be adjusted accordingly based on the sliding fee schedule. The Center is required to follow its sliding fee policy when providing discounts to eligible patients. Finding/ Condition: In our sample of 40 tested items three patients received the incorrect sliding fee discount based on the family size and income level. Questioned Cost: None. Effect: Lack of strict enforcement of the policy of sliding fee eligibility determination and compliance may have resulted in the Center providing discounted services greater to or less than the appropriate amounts to beneficiaries. Cause: Inadequate understanding of the sliding fee program requirements, how the electronic health record system processes sliding fee transactions, or Center policies by employees involved in sliding fee determination and billing. Recommendation: Training should be provided to employees on the sliding fee program requirements and how the program is managed by the electronic health record system. The Center should perform regular audits of sliding fee transactions to identify weaknesses in compliance. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding and is moving forward with its corrective action plan to address it. Please see page 31.

Corrective Action Plan

Name of Contact Person: Sarah Ross, Chief Operating Officer Corrective Action: Under the leadership of Open Door’s Chief Operations Officer and Director of Patient Access, we will implement the following actions to address SFDP compliance findings and reduce the risk of future errors. 1. Staff Retraining and Competency Validation Retrain all Office Managers and Front Office staff on SFDP requirements, documentation standards, and processing procedures in collaboration with EMR and Learning & Development. Staff will be required to successfully complete a knowledge check prior to independently handling SFDP documentation. SFDP training will also be incorporated into new-hire onboarding and reinforced through ongoing training as needed. 2. Ongoing Monitoring and Accountability Implement a formal monitoring and accountability process to ensure sustained compliance. SFDP accuracy will be reviewed weekly, with Front Office Managers maintaining an error log to track errors, trends, and corrective actions. Continued or repeated errors will be addressed through expectation conversations and progressive disciplinary action, while accurate and consistent performance will be recognized. 3. Monthly Reporting and Targeted Corrective Training Identify trends and common error types, utilizing monthly SFDP reporting, to inform targeted retraining and process improvements. The reporting infrastructure is currently being developed using the Smartsheet Intelligent Work Management Platform to support leadership oversight and continuous improvement. 4. Leadership Oversight and Site-Level Accountability Administrative Directors at all health centers will actively participate in SFDP oversight by meeting with staff to reinforce program expectations and consequences for non-compliance. Monthly site-level SFDP performance reviews will be conducted with the Director of Patient Access, Administrative Directors, and Office Managers to review findings, trends, and corrective actions. 5. Integration into Performance Evaluations SFDP compliance will be formally integrated into staff performance evaluations. Compliance measures are currently included in Office Manager scorecards and will be added to Receptionist performance evaluations to reinforce accountability and sustain compliance. 6. Process Improvement Through Automation To further reduce the risk of human error, Open Door is planning a transition toward increased SFDP automation within the EMR to standardize determinations and improve documentation accuracy over time. Proposed Completion Date: June 30, 2026

Categories

Special Tests & Provisions Eligibility

Programs in Audit

ALN Program Name Expenditures
93.493 CONGRESSIONAL DIRECTIVES $931,977
93.912 RURAL HEALTHCARE SERVICES PROGRAMS $738,887
93.918 GRANTS TO PROVIDE OUTPATIENT EARLY INTERVENTION SERVICES WITH RESPECT TO HIV DISEASE $422,774
93.224 HEALTH CENTER PROGRAM $37,416