Finding 1216215 (2025-001)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2025
Accepted
2026-06-01

AI Summary

  • Core Issue: Patients received sliding fee discounts that did not match the Health Center's established policy.
  • Impacted Requirements: Non-compliance with sliding fee discount criteria as per HRSA regulations and the Health Center's Compliance Manual.
  • Recommended Follow-up: Ensure all staff understand and follow the sliding fee scale policy; implement procedures for consistent discount application.

Finding Text

Health Center Program Cluster Assistance Listing Numbers 93.224 and 93.527 U.S. Department of Health and Human Services Criteria or Specific Requirement – Special Tests and Provisions: Sliding Fee Discounts (42 USC 254(k)(3)(g); 42 CFR sections 51c.303(g); and 42 CFR sections 56.303(f)). Condition – Patients received a sliding fee discount that was inconsistent with the stated sliding fee discount categories under the Health Center’s policy and Health Center Compliance Manual. Cause – The Health Center did not comply with their sliding fee policy and HRSA requirements for the program. Effect or Potential Effect – Sliding fee discounts were given to patients that were inconsistent with the Health Center’s sliding fee discount policy and Health Center Compliance Manual. Questioned Costs – None. Context – A sample of 40 encounters were tested out of the total population of 173,512 encounters. The sampling methodology used is not and is not intended to be statistically valid. Two patients received a sliding fee adjustment that was inconsistent with the Health Center’s sliding fee discount policy and Health Center Compliance Manual. Identification as a Repeat Finding – Repeat finding of 2024-001. Recommendation – It is recommended that management continue to ensure all personnel understand the sliding fee scale policy and adhere to the requirements and guidelines set forth in HRSA sliding fee program requirements. Procedures should be implemented to ensure that eligible patients receive discounts in accordance with the sliding fee scale and the Health Center Program Compliance Manual.

Corrective Action Plan

Views of Responsible Officials and Planned Corrective Actions – Description of Finding: Patients received a sliding fee discount that was inconsistent with the stated sliding fee discount categories under the Health Center’s policy. Statement of Concurrence: Shasta Community Health Center (SCHC) management acknowledges the finding and agrees that there were instances where the approved sliding fee policy of SCHC was misapplied. SCHC also recognizes that this is a repeat finding and recognize the need to strengthen controls to ensure full compliance with HRSA requirements. Root Cause: The identified errors were primarily due to: - Staff inattention in recognizing sliding fee discount expiration dates - Lack of clear guidance from management on sliding fee discounts related to nurse only or other generally unbillable patient visits - Lack of guidance in policies and procedures related to treatment of sliding fee discounts on nurse visits Corrective Action: - Management will reinforce through re-training of front office staff the importance of ensuring that sliding fee eligibility is carefully reviewed at each patient’s appointment. - Billing staff will be retrained in proper application of sliding fee discounts related to nurse-only visits. - Policy will be reviewed for any necessary changes and clarifications to nurse-only visits. - Electronic Health Record (EHR) system will be updated to correctly provide discounts based on patient’s sliding fee eligibility. Responsible Parties: - Front Office Retraining – Director of Informatics and Training - Billing Staff Retraining – Senior Director of Revenue Cycle Integrity and Billing Manager - Policy Revision – Chief Financial Officer and Senior Director of Revenue Cycle Integrity - EHR System Updates – Director of Informatics and Senior Director of Revenue Cycle Integrity Timeline: - Front Office Retraining – Next “All Staff Meeting”, currently scheduled for May 5, 2026. - Billing Staff Retraining – Billing meeting on April 29, 2026, to identify logistical issues and develop a plan to work through necessary EHR process revision. Full correction planned by June 30, 2026. - Policy Revision – Bring revised policy to board meeting in May 2026. - EHR System Updates – Full correction planned by June 30, 2026.

Categories

Special Tests & Provisions

Other Findings in this Audit

  • 1216214 2025-001
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
93.224 HEALTH CENTER PROGRAM (COMMUNITY HEALTH CENTERS, MIGRANT HEALTH CENTERS, HEALTH CARE FOR THE HOMELESS, AND PUBLIC HOUSING PRIMARY CARE) $5.53M
93.788 OPIOID STR $566,446
93.918 GRANTS TO PROVIDE OUTPATIENT EARLY INTERVENTION SERVICES WITH RESPECT TO HIV DISEASE $240,464
93.917 HIV CARE FORMULA GRANTS $204,783
93.734 EMPOWERING OLDER ADULTS AND ADULTS WITH DISABILITIES THROUGH CHRONIC DISEASE SELF-MANAGEMENT EDUCATION PROGRAMS – FINANCED BY PREVENTION AND PUBLIC HEALTH FUNDS (PPHF) $127,592
14.267 CONTINUUM OF CARE PROGRAM $125,086
93.527 GRANTS FOR NEW AND EXPANDED SERVICES UNDER THE HEALTH CENTER PROGRAM $39,427