Finding Text
Health Center Program Cluster – Assistance Listing Nos. 93.224 and 93.527 U.S Department of Health and Human Services Award No. 5 H80CS00681-23-07, June 1, 2024 – May 31, 2025 Award No. 6 H80CS00681-24-04, June 1, 2025 – May 31, 2026 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 sliding fee discounts that were inconsistent with the stated sliding fee discount categories under the Organization’s policy. Cause – The Organization did not comply with their sliding fee policy. Effect or potential effect– Sliding fee discounts were given to patients that were inconsistent with the Organization’s sliding fee discount policy. Questioned Costs – None Context – A selection of 25 encounters were testing out of the total population of 81,898 encounters. The sampling methodology used is not and is not intended to be statistically valid. Eleven encounters received a sliding fee adjustment that was inconsistent with the approved policy for the proper sliding fee adjustments based on their family size and household income documentation. Identification as a repeat finding, if applicable – Not a repeat finding. Recommendation – The Organization should ensure all personnel understand the sliding fee scale policy and adhere to the requirements and guidelines set forth in the policy. Procedures should be implemented and reviewed to ensure that eligible patients receive discounts in accordance with the sliding fee scale and the Health Center Program Compliance Manual. Views of Responsible Officials and Planned Corrective Actions – Management Response - Management concurs with the auditor's finding. The Organization acknowledges that patients received sliding fee discounts that were inconsistent with the stated sliding fee discount categories under the Organization's policy. Corrective Action Taken - (1) Crossing has implemented a billing workflow to automatically apply sliding fee scale discounts to all eligible self-pay accounts during the billing process, eliminating manual charge adjustments and improving consistency with established guidelines. (2) All billing staff have received retraining on the correct manual posting procedures for sliding fee scale adjustments after insurance payments, ensuring compliance with patient income verification and applicable percentage guidelines. (3) We will continue ongoing monitoring and review of accounts receiving sliding fee scale adjustments to ensure accurate and compliant application of the approved discount and percentages. Completion Date - Completed 4/1/26 Responsible Contact Person - Margret Guy, Director of Revenue; Julie Brilley, CEO