Finding 1236661 (2025-002)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2025
Accepted
2026-09-25

AI Summary

  • Core Issue: Sliding fee discounts were applied without proper documentation of patient family size and income.
  • Impacted Requirements: Compliance with federal regulations requiring accurate sliding fee discount schedules based on patient ability to pay.
  • Recommended Follow-up: Provide training for front desk staff on documentation processes and conduct regular internal audits to ensure compliance.

Finding Text

Special Tests and Provisions Federal Agency: U.S. Department of Health and Human Services Federal Program Title: Health Center Program Cluster Assistance Listing Numbers: 93.224 Federal Award Identification Number and Year: H80CS00034-23; H80CS00034-24 Award Period: February 1, 2024 – January 31, 2025; February 1, 2025 – January 31, 2026 Criteria or specific requirement: 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. (42 USC 254b(k)(3)(G); 42 CFR sections 51c.303(f), and (g); and 42 CFR sections 56.303(f), and (g)). Condition: Sliding fee discounts were applied to patient encounters with insufficient documentation being obtained or maintained related to patient family size and income. In these instances, the Organization provided a sliding fee discount despite not having documentation to support the discount applied. Questioned costs: None. Context: Ten (10) of sixty (60) encounters received a sliding fee adjustment without a completed patient application with family size and income. For 8 of these 10 instances, the Organization obtained a completed application and supporting documents for a visit subsequent to the visit selected for testing. Cause: Oversight. Effect: Patient may receive a discount when not eligible or may receive a discount for the wrong amount. Repeat Finding: Yes, prior year finding 2024-001. Recommendation: Management should provide additional training and education to front desk staff related to the process for collecting family size and income information, along with inputting it into the electronic medical records. We also recommend performing and documenting regular internal audits of patient visits to determine whether all required patient information has been obtained in accordance with the Organization's policies. Views of responsible officials: There is no disagreement with this finding.

Corrective Action Plan

Health Center Program – Assistance Listing No. 93.224 Recommendation: Management should provide additional training and education to front desk staff related to the process for collecting family size and income information, along with inputting it into the electronic medical records. We also recommend performing and documenting regular internal audits of patient visits to determine whether all required patient information has been obtained in accordance with the Organization's policies. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: OCHC has hired a new PSR Supervisor to oversee the sliding fee process. Audits will be performed on all sliding fee applications. The PSR Supervisor will train all PSR Staff on the policy. New hires will receive this training during onboarding, and all staff will receive annual refresher. Perform and document monthly internal audits of a sample of patient visits and sliding fee applications to verify that all required information was obtained in accordance with organizational policy. Audit results will be logged, reviewed with staff, and reported to leadership quarterly. Conduct follow-up retraining and correction action when deficiencies are identified. Name(s) of the contact person(s) responsible for corrective action: Tangela Poole, CFO Planned completion date for corrective action plan: 12/31/2026

Categories

Special Tests & Provisions Internal Control / Segregation of Duties

Programs in Audit

ALN Program Name Expenditures
93.224 HEALTH CENTER PROGRAM $3.10M
14.267 CONTINUUM OF CARE PROGRAM $458,537
93.493 CONGRESSIONAL DIRECTIVES $218,842
93.150 PROJECTS FOR ASSISTANCE IN TRANSITION FROM HOMELESSNESS (PATH) $199,333
93.958 BLOCK GRANTS FOR COMMUNITY MENTAL HEALTH SERVICES $79,828
21.027 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $52,343
93.268 IMMUNIZATION COOPERATIVE AGREEMENTS $8,121