Finding 1237570 (2025-003)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2025
Accepted
2026-09-28
Audit: 412514
Auditor: SJT GROUP LLC

AI Summary

  • Core Issue: One medical claim out of 50 did not apply the sliding fee discount at the time of service, leading to non-compliance with federal regulations.
  • Impacted Requirements: FCCH failed to follow its own policies and 42 CFR Part 51c.303(f) regarding fee schedules and discounts based on patient income.
  • Recommended Follow-Up: FCCH should enforce its policies on fee adjustments and conduct a review of medical claims to identify similar errors.

Finding Text

2025-003—Special Tests and Provisions—Sliding Fee Discount Program Federal program information: Funding agency: U.S. Department of Health and Human Services Title: Health Center Cluster Assistance Listing Number (ALN): 93.224 Award number and year: H80CS00202 (1/1/2025 – 12/31/2025) Criteria: According to 42 CFR Part 51c.303(f) and FCCH’s Sliding Fee Discount and Related Billing and Collections Program Policies and Procedures, a community health center must have prepared a schedule of fees or payments for the provision of its services designed to cover its reasonable costs of operation and a corresponding schedule of discounts adjusted on the basis of the patient's ability to pay, provided that such schedule of discounts shall provide for a full discount to individuals and families with annual incomes at or below those set forth in the poverty guidelines updated periodically in the Federal Register by the U.S. Department of Health and Human Services under the authority of 42 U.S.C. 9902(2); and for no discount to individuals and families with annual incomes greater than twice those set forth in such guidelines. Condition: For one of 50 medical claims tested, the sliding fee discount was not applied to the patient’s account at the date of service. FCCH appropriately only collected 20% of the billed amount under the Sliding Fee Discount Program (SFDP) based on the patient’s income level. However, the remaining 80% of the billed amount was not adjusted off the patient account until the claim was tested as part of the audit. Questioned Costs: None Context: One of 50 medical claims tested. Cause: FCCH’s Sliding Fee Discount and Related Billing and Collections Program Policies and Procedures were not followed. Effect: FCCH is not in compliance with 42 CFR Part 51c.303(f). Additionally, FCCH is not in compliance with its Sliding Fee Discount and Related Billing and Collections Program Policies and Procedures. Auditor’s Recommendation: FCCH should implement its established policies and procedures which require adherence to the approved schedule of fees for services and discounts. FCCH should also consider performing its own review of medical claims billed to determine the prevalence of these errors.

Corrective Action Plan

2025-003—Special Tests and Provisions—Sliding Fee Discount Program Corrective Action: Management concurs with the finding. Management recognizes the importance of timely and accurate application of sliding fee discounts to ensure compliance with approved fee schedules, accurate patient account balances, and proper financial reporting. Management will reinforce adherence to existing policies and procedures, provide staff reeducation, and perform a retrospective review of applicable claims to determine whether similar errors exist. Corrective actions and monitoring activities are outlined below.  Review and reissue the Sliding Fee Discount Program policy and procedures to all Patient Service Representatives, and Billing staff. Require staff acknowledgment of understanding.  Conduct mandatory staff training on the proper application of sliding fee discounts, including the requirement that discounts and write-offs be posted to patient accounts at the time services are rendered or when eligibility is determined. Perform a retrospective review of all sliding fee discount encounters for the prior 12 months to identify accounts where discounts were collected but corresponding adjustments were not timely posted. Correct identified accounts and document findings.  Quantify the prevalence of the error, determine root causes, and report results to executive leadership.  Implement a monthly monitoring process that includes a sample review of sliding fee discount accounts to verify that discounts are accurately applied and adjusted on the date of service or in accordance with policy requirements.  Report monitoring results quarterly to leadership and take corrective action as needed for any recurring issues identified. Person Responsible: Tammy Collins, Revenue Cycle Director Completion Date: January 31, 2027

Categories

Special Tests & Provisions

Programs in Audit

ALN Program Name Expenditures
93.224 HEALTH CENTER PROGRAM $7.65M
93.526 GRANTS FOR CAPITAL DEVELOPMENT IN HEALTH CENTERS $319,254
93.778 GRANTS TO STATES FOR MEDICAID $77,449