Johnson Health Center will strengthen its processes and oversight related to the Sliding Fee Discount Program to ensure staff are consistently applying the sliding fee process in accordance with JHC policies and applicable requirements. The Billing Department will develop a comprehensive training manual for front-end staff that outlines the proper procedures for determining and documenting sliding fee eligibility and applying the appropriate discount. In addition to the written training materials, the Billing Department will provide hands-on, on-the-job training to ensure staff understand how to properly complete each step of the sliding fee process. The Billing Department currently performs monthly audits of sliding fee transactions to identify errors and ensure the process is being followed appropriately. Going forward, our Director of Compliance will have a more active role in the monthly monitoring process. The Director of Compliance will review the Billing Department's monthly audit results and supporting documentation to validate that findings are accurate, complete, and appropriately addressed. Any identified issues will be communicated to the appropriate staff and corrected timely. This additional oversight will provide an independent review of the monthly monitoring process and help ensure that identified deficiencies are properly addressed and that the sliding fee process remains compliant on an ongoing basis. JHC will also implement a progressive disciplinary process for repeated failure to follow the Sliding Fee Discount Program procedures. The disciplinary actions will be applied as follows: • First occurrence: One-on-one counseling and review of the applicable procedures. • Second occurrence: Verbal warning and additional training. • Third occurrence: Written warning. • Fourth occurrence: Further disciplinary action, up to and including termination. The training manual and additional staff training will be implemented as part of JHC's corrective action process. Monthly monitoring by the Billing Department, with additional review by the Compliance Officer, will continue on an ongoing basis to ensure the corrective actions remain effective and that any future issues are identified and addressed promptly.