Finding 1226000 (2025-002)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2025
Accepted
2026-08-06
Audit: 408670
Organization: Piedmont Health Services, Inc. (NC)

AI Summary

  • Core Issue: Patients received sliding fee discounts that did not match the organization's policy categories.
  • Impacted Requirements: Compliance with sliding fee discount policies as outlined in federal regulations (42 USC 254 and 42 CFR sections 51c.303 and 56.303).
  • Recommended Follow-Up: Ensure all staff understand and follow the sliding fee scale policy; implement procedures for consistent application of discounts.

Finding Text

Health Center Program Cluster Assistance Listing Numbers 93.224 and 93.527 U.S. Department of Health and Human Services Award No. 6 H80CS00086-24-10 Program Year 25 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 a sliding fee discount that was 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 sample of 25 patients were tested out of the total population of 132,315 encounters. The sampling methodology used is not and is not intended to be statistically valid. Three patients received a sliding fee adjustment that was inconsistent with the approved policy based on their income determination. Identification as a repeat finding – Not a repeat finding Recommendation - We recommend management continue to 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 to ensure that eligible patients receive discounts in accordance with the sliding fee scale and the Health Center Program Compliance Manual.

Corrective Action Plan

Views of Responsible Officials and Planned Corrective Actions – Management agrees that the Sliding scale has been incorrectly applied on patient accounts and intends to do the following: A root cause analysis should determine whether the errors resulted from: • Staff calculation errors when annualizing income. • Failure to properly verify income documentation. • Incorrect data entry in the practice management system. • Inadequate training on sliding fee eligibility determination procedures. • Lack of secondary review or quality assurance monitoring by the revenue cycle team. In addition to the root cause analysis Piedmont Health Services will do the following: 1. Correct the three identified patient accounts and process any necessary refunds, adjustments, or account corrections. 2. Conduct a targeted review of a broader sample of recent sliding fee determinations to identify any additional errors and implement corrective action where necessary. 3. Retrain registration, eligibility, and financial counseling staff on income verification requirements, family-size determination, documentation standards, and sliding fee calculation procedures. 4. Implement secondary review procedures for sliding fee determinations until system enhancements are in place. 5. Continue monthly quality assurance audits of sliding fee eligibility determinations and monitor error rates. 6. Transition to OCHIN Epic in August 2026. The new EMR platform is expected to significantly strengthen internal controls through enhanced workflow automation, improved documentation, standardized eligibility processes, and expanded reporting capabilities. These features will provide greater visibility into sliding fee eligibility determinations, improve management's ability to monitor compliance, and reduce the risk of manual calculation and data-entry errors. 7. Following Epic implementation, management will conduct post-go-live validation testing to confirm that sliding fee determinations are functioning as designed and that eligibility calculations are accurate and compliant with HRSA requirements. Expected Outcome The combination of staff retraining, enhanced monitoring, and migration to OCHIN Epic is expected to improve the accuracy of sliding fee eligibility determinations, strengthen compliance oversight, and reduce the risk of future errors. The Director of Revenue and the CFO will monitor error rates through periodic audits and leverage Epic reporting tools to support ongoing compliance and quality assurance efforts. Individuals Responsible Beth Moseley, Chief Financial Officer and Daniella Jaimes-Colina, Chief Executive Officer

Categories

Questioned Costs Special Tests & Provisions

Other Findings in this Audit

  • 1225997 2025-002
    Material Weakness Repeat
  • 1225998 2025-002
    Material Weakness Repeat
  • 1225999 2025-002
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
10.557 WIC SPECIAL SUPPLEMENTAL NUTRITION PROGRAM FOR WOMEN, INFANTS, AND CHILDREN $1.20M
93.884 PRIMARY CARE TRAINING AND ENHANCEMENT $354,870
93.224 HEALTH CENTER PROGRAM $327,656
93.527 GRANTS FOR NEW AND EXPANDED SERVICES UNDER THE HEALTH CENTER PROGRAM $164,439
93.318 PROTECTING AND IMPROVING HEALTH GLOBALLY: BUILDING AND STRENGTHENING PUBLIC HEALTH IMPACT, SYSTEMS, CAPACITY AND SECURITY $79,840
93.959 BLOCK GRANTS FOR PREVENTION AND TREATMENT OF SUBSTANCE ABUSE $76,159
93.837 CARDIOVASCULAR DISEASES RESEARCH $73,230
93.117 PREVENTIVE MEDICINE RESIDENCY $72,844
93.917 HIV CARE FORMULA GRANTS $60,243
93.918 GRANTS TO PROVIDE OUTPATIENT EARLY INTERVENTION SERVICES WITH RESPECT TO HIV DISEASE $59,036
93.969 PPHF GERIATRIC EDUCATION CENTERS $22,782
93.088 ADVANCING SYSTEM IMPROVEMENTS FOR KEY ISSUES IN WOMEN'S HEALTH $19,406