Finding 1236328 (2025-001)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2025
Accepted
2026-09-24

AI Summary

  • Core Issue: The health center did not consistently document patient assessments for the sliding fee discount, leading to potential non-compliance.
  • Impacted Requirements: This affects the Special Tests compliance requirement for the grant and indicates a significant deficiency in internal controls.
  • Recommended Follow-Up: Ensure the Sliding Fee Discount Form is completed for every patient at their first visit and updated annually, and create a monitoring tool to check the effectiveness of this process.

Finding Text

Grantee 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. The Organization adopted a Sliding Fee Discount Schedule based on current Federal poverty guidelines; however, they failed to consistently document the patient's assessment for the discount and retain the patient's application. 3 out of 25 patients tested did not have documentation of the sliding fee discount assessment. We were unable to determine whether the sliding fee discount was properly applied to these patients. The effect is reportable non-compliance with the Special Tests compliance requirement for this grant. Further, the Organization has a significant deficiency in internal controls over compliance. The Organization's internal control over compliance was properly designed to ensure patients were assessed for ability to pay; however, it was not operating effectively during the period under audit. It is recommended that the Organization ensure that the Sliding Fee Discount Form is completed for every patient on their initial visit, updated annually, and included within their patient record. The form documents the patient's household income and eligible dependents to properly assess their ability to pay based upon the Federal poverty guidelines. Futher, it is recommended that the Organization develop a monitoring tool to detect when this control may not be operating effectively.

Corrective Action Plan

Previous corrective actions included revised registration forms, pre-visit schedule preparation, post-visit audits, and staff training. While these measures improved monitoring, SHR identified the need for stronger point-of-service controls and increased operational oversight. We are revising our SFS and front-office policies and procedures to clearly define documentation requirements, staff responsibilities, and management accountability. A key revision will require patients requesting or renewing SFS eligibility to provide all required documentation at the time of service. The previous process allowing additional time after the visit to submit documentation will be discontinued. Patients without required documentation will be handled according to the revised policy regarding SFS eligibility and financial responsibility. SHR is also establishing an Assistant Director of Operations (ADOO) position responsible for standardized front-office training, monitoring, and accountability across all clinic locations. The ADOO will train front-office staff and Clinic Managers on SFS eligibility requirements, point-of-service documentation, and revised policies and procedures.The ADOO will conduct routine audits of SFS eligibility records and front-office documentation. Deficiencies will be documented and addressed with the applicable Clinic Manager and staff through retraining, corrective follow-up, and accountability measures as appropriate. Corrective actions will be tracked through resolution, with recurring or significant deficiencies escalated through Operations leadership. These strengthened point-of-service requirements, revised policies, standardized training, routine auditing, and defined accountability measures will provide SHR with a consistent process for identifying and correcting deficiencies and supporting sustained SFS compliance across all clinic locations.

Categories

Subrecipient Monitoring Significant Deficiency Internal Control / Segregation of Duties Special Tests & Provisions

Other Findings in this Audit

  • 1236329 2025-002
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
93.243 SUBSTANCE ABUSE AND MENTAL HEALTH SERVICES PROJECTS OF REGIONAL AND NATIONAL SIGNIFICANCE $2.36M
93.224 HEALTH CENTER PROGRAM (COMMUNITY HEALTH CENTERS, MIGRANT HEALTH CENTERS, HEALTH CARE FOR THE HOMELESS, AND PUBLIC HOUSING PRIMARY CARE) $1.39M
14.241 HOUSING OPPORTUNITIES FOR PERSONS WITH AIDS $1.03M
93.917 HIV CARE FORMULA GRANTS $952,106
93.939 HIV PREVENTION ACTIVITIES NON-GOVERNMENTAL ORGANIZATION BASED $450,206
93.918 GRANTS TO PROVIDE OUTPATIENT EARLY INTERVENTION SERVICES WITH RESPECT TO HIV DISEASE $221,842
93.217 FAMILY PLANNING SERVICES $205,854
93.940 HIV PREVENTION AND SURVEILLANCE ACTIVITIES-HEALTH DEPARTMENT BASED $187,779