Finding 1224345 (2025-001)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2025
Accepted
2026-07-22

AI Summary

  • Core Issue: The organization failed to retain signed sliding fee attestation forms, which are essential for determining patient discount levels based on income and family size.
  • Impacted Requirements: This oversight increases the risk of incorrect fee assignments and potential noncompliance with regulatory requirements for the year ended December 31, 2025.
  • Recommended Follow-Up: Implement training for staff on documentation retention, establish monitoring controls, and conduct internal audits to ensure compliance with sliding fee policies.

Finding Text

U.S. Department of Health and Human Services, COVID-19 Health Center Program Cluster (Assistance Listing Number 93.224/93.527) Item 2025-001 - Special Tests and Provisions Criteria Health centers are required to have a corresponding schedule of discounts applied and adjusted on the basis of patients' ability to pay and their eligibility. A patient's eligibility to pay is determined on the basis of the official poverty guideline, as revised by DHHS (42 CFR Sections 51c, 107(b)(5), 56.108(b)(5) and 56.303(f)). Statement of Condition While performing our audit, we noted that the Organization did not retain the signed sliding fee attestation form that documented patient income level and family size and therefore there was no basis to correctly determine slide level in effect for the year ended December 31, 2025. Cause The condition can be attributed to human error and the lack of internal controls to review and ensure that the proper sliding fee documentation is being maintained and applied. Effect The Center’s failure to retain signed sliding fee attestation forms results in an inability to verify patient income and family size used to determine appropriate discount levels, increasing the risk of incorrect fee assignments, potential noncompliance with regulatory and program requirements, for year ended December 31, 2025. Questioned Costs None Context While performing our audit, we noted that the Organization did not retain the signed sliding fee attestation form that documented patient income level and family size to calculate sliding fee discount category given to two out of forty patients selected for testing for the year ended December 31, 2025. Identification as a Repeat Finding This is a repeat finding. (See prior year finding number 2024-001) Recommendation We recommend that proper training be given to employees at registration to ensure that proper documentation from the patients, such as the signed sliding fee attestation form, is maintained and kept on file to support the correct application of sliding fee discounts. Supervisors should also have controls in place in monitoring and reviewing the sliding fee calculations on a periodic basis to ensure compliance with the sliding fee scale, along with proper retention policies. In addition, management should conduct internal audits to ensure the sliding fee is calculated properly and that signed attestation forms are properly retained. Views of Responsible Official Management agrees with the recommendations. During 2025, DVCH’s front desk staff started to assume more responsibility for conducting the sliding fee categorization. This additional staff had training and is gaining experience. Management will ensure training, monitoring, auditing, and supervision is adequate to ensure registration properly documents the signed sliding fee attestation form. DVCH expects to adopt a software solution for sliding fee categorization in 2026. The software solution will make common errors less common by automating several manual processes.

Corrective Action Plan

Management agrees with the recommendations. During 2025, DVCH’s front desk staff started to assume more responsibility for conducting the sliding fee categorization. This additional staff had training and is gaining experience. Management will ensure training, monitoring, auditing, and supervision is adequate to ensure registration properly documents the signed sliding fee attestation form. DVCH expects to adopt a software solution for sliding fee categorization in 2026. The software solution will make common errors less common by automating several manual processes. If the Health Resources and Services Administration has questions regarding this plan, please call Ryan Taylor, Chief Financial Officer, at taylorr@dvch or 267-240-2578.

Categories

Special Tests & Provisions Subrecipient Monitoring Eligibility Internal Control / Segregation of Duties

Other Findings in this Audit

  • 1224344 2025-001
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
93.224 CONSOLIDATED HEALTH CENTERS (COMMUNITY HEALTH CENTERS, MIGRANT HEALTH CENTERS, HEALTH CARE FOR THE HOMELESS, AND PUBLIC HOUSING PRIMARY CARE) $6.61M
93.530 AFFORDABLE CARE ACT - TEACHING HEALTH CENTER GRADUATE MEDICAL EDUCATION PAYMENTS PROGRAM $989,002
93.526 AFFORDABLE CARE ACT (ACA) GRANTS FOR CAPITAL DEVELOPMENT IN HEALTH CENTERS $864,291
93.914 HIV EMERGENCY RELIEF PROJECT GRANTS $166,730
93.988 COOPERATIVE AGREEMENTS FOR STATE-BASED DIABETES CONTROL PROGRAMS AND EVALUATION OF SURVEILLANCE SYSTEMS $110,231
93.527 AFFORDABLE CARE ACT (ACA) GRANTS FOR NEW AND EXPANDED SERVICES UNDER THE HEALTH CENTER PROGRAM $54,881
93.323 EPIDEMIOLOGY AND LABORATORY CAPACITY FOR INFECTIOUS DISEASES (ELC) $21,016
93.686 ENDING THE HIV EPIDEMIC: A PLAN FOR AMERICA — RYAN WHITE HIV/AIDS PROGRAM PARTS A AND B (B) $20,000
93.268 IMMUNIZATION COOPERATIVE AGREEMENTS $15,235