Finding Text
FINDING 2025-002 – SLIDING SCALE FEES Identification of Federal Program U.S. Department of Health and Human Services (DHHS) 93.224 / 93.527 – Health Center Cluster Special Tests and Provisions MATERIAL WEAKNESS, NON-COMPLIANCE Criteria – Health centers are required to have a schedule of discounts to be applied and adjusted based on the patients’ ability to pay and eligibility. A patient’s eligibility to pay is determined based on the official poverty guideline, as revised by DHHS (42 CFR Sections 51c, 107(b)(5), 56.108(b)(5), and 56.303(f). The Organization exercises monitoring procedures to properly determine, calculate, and review sliding fee discounts to patients in accordance with the Organization’s sliding fee scale. Condition – The Organization did not perform a review of patient registration forms by employees knowledgeable about the program's parameters. Further, in many instances, inadequate documentation was maintained in patient files. Questioned Costs – The identified exceptions relate to the application of the Organization’s sliding fee discount program and resulted in variances in patient charges in both directions. Because the exceptions did not involve the use of federal award funds and did not result in unsupported, unallowable, or ineligible expenditures, there were no questioned costs associated with this finding. Context – During our audit we noted that 41 of 41 patient encounters sampled did not have evidence of review on the patient registration forms. Further, for 19 of 41 patient encounters sampled, sliding fees were calculated improperly. For 3 of 41 patient encounters sampled, proof of income was improper or inadequately documented. For 1 of 41 patient encounters sampled, billing was not performed in accordance with the proper sliding scale. Effect or Potential Effect – The Organization did not comply with the determination of sliding fee discounts based on the federal poverty guidelines in effect for the year ended April 30, 2025. In addition, the Organization may not have properly calculated the sliding fee discount given to the patients, and the discount given, if any, may not have been based on the patient’s ability to pay. Further, adequate documentation is not always maintained in patient files. Cause – Policies and procedures were not followed to ensure adequate review of patient registration forms by persons knowledgeable about the program's parameters. Further policies and procedures were not followed to ensure adequate documentation is maintained in patient files. Repeat Findings – This finding is similar to finding 2024-002 issued last year. Recommendation – We recommend that the Organization continue to train and develop new personnel on specific processes related to compliance requirements. In addition, the Organization should establish a review process to ensure that sliding scale charges are monitored and reviewed by a supervisor on a periodic basis to ensure compliance and to ensure adequate records are maintained. Views of Responsible Officials – Management agrees with the finding and the auditors’ recommendation. See Corrective Action Plan at the end of the report.