Finding 1223515 (2025-001)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2025
Accepted
2026-07-10

AI Summary

  • Core Issue: There is a material weakness in the application of sliding fee discounts, with 20% of tested encounters incorrectly discounted.
  • Impacted Requirements: Compliance with Health Center Program guidelines (AL # 93.224 and 93.527) regarding patient sliding fee applications.
  • Recommended Follow-Up: Ensure all sliding fee applications are completed before billing and implement regular internal checks to verify compliance.

Finding Text

2025-001, 2024-001, 2023-001, 2022-001, 2021-001 – Material Weakness and Material Noncompliance – Special Tests – Sliding Fee Program information: AL # 93.224 and 93.527, Health Center Program Cluster, Department of Health and Human Services. Criteria: Health centers must obtain sliding fee applications so that amounts owed for health center services by eligible patients are adjusted (discounted) based on the patient’s ability to pay. Condition: We tested 60 sliding fee encounters and noted that 12 out of 60 sliding fee encounters tested were discounted the incorrect amount. Questioned Costs: None Cause and Effect: The Center failed to verify sliding fee discounts were applied correctly to charges. Recommendation: We recommend that sliding fee applications be completed for each sliding fee patient. Procedures should be implemented to verify applications are completed before the encounter is billed. Sliding fee discounts per policy should be agreed in the billing system to ensure the proper discounts are entered and updated. In addition, the Center could consider increasing its internal sampling throughout the year to verify sliding fee applications are obtained, completed, and agree to the discount applied. Views of Responsible Officials: Management agrees with the finding. Corrective Action Plan: See attached correct plan.

Corrective Action Plan

Finding Number: 2025-001, 2024-001, 2023 01, 2022-001, 2021-001: Material Weakness and Material Noncompliance - Sliding Fee Recommendation We recommend that sliding fee applications be completed for each sliding fee patient. Procedures should be implemented to verify that applications are completed before the encounter is billed. Sliding fee discounts per policy should be agreed upon in the billing system to ensure the proper discounts are entered into and updated. In addition, the Center could consider increasing its internal sampling throughout the year to verify that sliding fee applications are obtained, completed, and agree to the discount applied. Action Taken CHASS management concurs with the audit findings and will put the following corrective action plan in place to mitigate this finding in the future. CHASS has developed and implemented a comprehensive series of improvements. After the last fiscal audit (March 2025), it was discovered that the EPIC system had the old Sliding Fee Schedule that had not been updated since 2022 (https://aspe.hhs.gov/poverty-guidelines ). The new sliding fee schedule was implemented in the EPIC system, and since then, the fee schedule has been updated as the government guidelines change (February). Continuing the current implementation will reinforce the process of verification of patients receiving a sliding fee discount. To achieve this, the Center's Customer Service team now generates personalized labels for each eligible patient and cross-checks their entries by the end of each day. The Supervisor/Team Leader will continue to conduct a second review of the labels to ensure the accuracy of the data for each patient utilizing the sliding scale discount program. This review also includes the actual charges in EPIC and the discount being verified with CPT Tables. Third implementation, Clinical Intern Staff will be responsible for reviewing encounters to ensure that the CPT code is correct and charges on patients' accounts have the appropriate sliding scale fee applied. They will be utilizing direct reports from EPIC on all Slide Fee encounters. Any discrepancies will be immediately forwarded to the supervisor for corrections and adjustments. Fourth implementation, the Center's Billing Department is now responsible for performing regular quarterly audits, sampling at least 40 encounters. During these audits, they look at sliding fee discounts and examine the applied fees and the corresponding discounts applied to the patient's account (using the approved CPT Table). This process will also include what sliding discount the patient qualifies for according to their income and family size. Results of the audit will be forwarded to the Chief Operations Officer to review and address appropriately. Through these improvements, CHASS aims to ensure that the Sliding Fee Discount Policy is used accurately and appropriately. These methods have been incorporated into the Center's Sliding Fee Discount Policy to guarantee their utilization and accuracy, and to further strengthen the Center's initiatives in providing access to needed health care services. Responsible Parties: Mariana Guitierrez, Billing Manager, and Angela Salgado, Interim Chief Financial Officer

Categories

Material Weakness Special Tests & Provisions

Other Findings in this Audit

  • 1223511 2025-001
    Material Weakness Repeat
  • 1223512 2025-003
    Material Weakness Repeat
  • 1223513 2025-001
    Material Weakness Repeat
  • 1223514 2025-003
    Material Weakness Repeat
  • 1223516 2025-003
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
21.027 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $416,771
10.557 WIC SPECIAL SUPPLEMENTAL NUTRITION PROGRAM FOR WOMEN, INFANTS, AND CHILDREN $331,486
93.224 HEALTH CENTER PROGRAM $197,370
16.588 VIOLENCE AGAINST WOMEN FORMULA GRANTS $145,929
16.888 CONSOLIDATED AND TECHNICAL ASSISTANCE GRANT PROGRAM TO ADDRESS CHILDREN AND YOUTH EXPERIENCING DOMESTIC AND SEXUAL VIOLENCE AND ENGAGE MEN AND BOYS AS ALLIES $142,830
16.017 SEXUAL ASSAULT SERVICES FORMULA PROGRAM $106,875
16.016 CULTURALLY AND LINGUISTICALLY SPECIFIC SERVICES PROGRAM $98,996
93.671 FAMILY VIOLENCE PREVENTION AND SERVICES/DOMESTIC VIOLENCE SHELTER AND SUPPORTIVE SERVICES $96,921
16.575 CRIME VICTIM ASSISTANCE $92,611
16.524 LEGAL ASSISTANCE FOR VICTIMS $87,611
93.332 COOPERATIVE AGREEMENT TO SUPPORT NAVIGATORS IN FEDERALLY-FACILITATED EXCHANGES $63,711
93.778 GRANTS TO STATES FOR MEDICAID $13,080
93.527 GRANTS FOR NEW AND EXPANDED SERVICES UNDER THE HEALTH CENTER PROGRAM $6,523