Finding 1229166 (2025-003)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2025
Accepted
2026-09-09

AI Summary

  • Core Issue: Patients received incorrect sliding fee discounts due to non-compliance with the Organization's policy.
  • Impacted Requirements: The sliding fee scale was not updated timely with annual poverty guideline changes.
  • Recommended Follow-Up: Ensure staff understand and follow the sliding fee policy, and implement procedures for annual updates to the sliding fee scale.

Finding Text

Health Center Program Cluster Assistance Listing 93.224 and 93.527 U.S. Department of Health and Human Services Award No. 2 H80CS26560-12-00 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 documented sliding fee discount categories under the Organization's Policy. In addition, the Organization did not update the sliding fee scale for annual changes to the poverty guidelines timely. Cause: The Organization did not comply with its sliding fee policy. Effect or Potential Effect: Incorrect sliding fee discounts were given. Questioned Costs: None Context: A sample of 40 patients was tested out of the total population of 1,452 encounters and 11 errors were noted where patients received an incorrect sliding fee adjustment. The sampling methodology used is not and is not intended to be statistically valid. Identification as a Repeat Finding: Repeat Finding of 2024-003 Recommendation: We recommend that management continue to ensure that 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. In addition, management should ensure the Organization's sliding fee scale is updated annually in accordance with federal guidelines.

Corrective Action Plan

Views of Responsible Officials and Planned Corrective Action: A more formal sliding fee training procedure was developed in 2026 and was administered to staff in June 2026. This training includes identifying patients, completing the application, income and household verifications, determination of the correct fee schedule and how to check for accuracy. Along with this training, a process of weekly audits was implemented to check for accuracy and determine the need for any coaching or retraining. This is one of many training topics that are now in a regular, repeating rotation so the training will be recurring. A new Sliding Fee Discount Policy was approved by the Board of Directors on March 21, 2025 and March 19, 2026. The Sliding Fee Discount Schedule is on the board schedule to be review annually in conjunction with the updated federal poverty guidelines when they are issued. There has been a workflow developed for distributing t his information once the new Sliding Fee Discount Schedule is approved by the board of directors.

Categories

Special Tests & Provisions

Other Findings in this Audit

  • 1229164 2025-003
    Material Weakness Repeat
  • 1229165 2025-003
    Material Weakness Repeat
  • 1229167 2025-004
    Material Weakness Repeat
  • 1229168 2025-004
    Material Weakness Repeat
  • 1229169 2025-004
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
93.224 HEALTH CENTER PROGRAM $400,000
93.527 GRANTS FOR NEW AND EXPANDED SERVICES UNDER THE HEALTH CENTER PROGRAM $46,521
93.778 GRANTS TO STATES FOR MEDICAID $13,157
93.912 RURAL HEALTHCARE SERVICES PROGRAMS $10,000