Finding Text
2025-005 Special Tests (repeat of finding 2024-005) Program Information Federal Agency U.S. Department of Health and Human Services Assistance Listing Numbers 93.224 Health Centers Program Cluster Award Numbers H80CS00055, H8GCS48089 Criteria OMB 2 CFR 200, Subpart F Compliance Supplement, Part 4, Compliance Requirement N, Special Tests and Provisions states, “Health Centers must prepare and apply a sliding fee discount schedule so that the amounts owed for health center services by eligible patients are adjusted (discounted) based on the patient’s ability to pay.” [X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness Condition During our testing of sliding fee discounts for health center patients qualifying for reduced charge visits, we identified incidents in which the sliding fee applied was not consistent with the entities’ policies based on the patient’s level of income. This finding appears to be a systemic problem. Cause Due to turnover in the billing and admitting staff, there was lack of appropriate training relating to the requirements of the sliding fee system to properly administer the sliding fee program. In addition, the billing software was not properly updated for changes in the sliding fee scale to apply the sliding fees correctly based on the levels supported by the patient applications. Effect Patients may have been granted the incorrect sliding fee adjustment. Questioned Costs None identified. Context A sample size of 25 patients included 12 who did not have the correct sliding fee applied. The misapplied sliding fees were due to lack of current application on file. Recommendation We recommend continued effort in training personnel on applying the appropriate sliding fee discount based on the Clinic’s approved policy and in compliance with the OMB Compliance Supplement requirements. An appropriate level of review should be conducted on patient accounts to ensure proper document retention, application of sliding fee discounts, and thirdparty insurance billing. Views of responsible officials and planned corrective action White Bird Clinic agrees with this finding. White Bird Clinic has created and hired for a new position, Revenue Cycle Manager (RCM). The RCM has oversight of Revenue generated through the FQHC Clinics. As part of this oversight the RCM is implementing training for Front Office staff that are responsible for gathering and inputting client data related to calculation of the Slide. In addition to internal training of Front Office staff, White Bird Clinic will be engaging an external expert to review and revise applicable policies and procedures to ensure alignment with best practices. The RCM is also responsible for conducting periodic internal reviews of documentation supporting Slide calculations to ensure support matches with the calculated Slide rate.