Finding Text
Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Health Center Program Cluster Assistance Listing Number: 93.224 Federal Award Identification Number and Year: H8029021 Award Period: June 1, 2024 - May 31, 2027 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or specific requirement: The Health Resources and Services Administration (HRSA), as reflected in the OMB Compliance Supplement for the Health Center Program, requires health centers to maintain and consistently apply a sliding fee discount program (SFDP) based on patients’ documented household income and family size. Discounts must be determined using current, complete applications with supporting documentation, and applied in accordance with the approved sliding fee schedule. Patients who do not provide sufficient income information are not eligible for sliding fee discounts. Condition: The Organization applied a sliding fee adjustment incorrectly to 2 of 40 patient accounts tested. Questioned costs: None Context: In a sample of 40: • One instance was noted where the discount level applied (e.g., Slide A) did not align with the sliding fee application income reported, which supported a different discount eligibility (e.g., Slide B). • One instance was noted where a sliding fee discount was applied to a patient's balance, however, a sliding fee application was not received from the patient. Cause: The noncompliance appears to result from inadequate internal controls over the review and approval of sliding fee applications, including: • Insufficient verification of income documentation prior to assigning discount levels • Lack of a control to ensure a completed application is on file before applying discounts • Inconsistent application of policies by staff responsible for patient eligibility determinations Effect: Patients may have received discounts that were not in accordance with HRSA requirements. Repeat Finding: No Recommendation: We recommend the following controls be put into place: • Implement a secondary review or approval control to validate that assigned discount levels align with documented income • Periodically test a sample of sliding fee determinations to ensure consistent application of the fee schedule • Provide training to registration and billing staff to reinforce SFDP requirements and documentation standards Views of responsible officials: Management agrees with the above finding and has since implemented an additional review of all sliding fee applications received and additional training for intake staff.