Finding 1238717 (2025-003)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2025
Accepted
2026-09-30

AI Summary

  • Core Issue: Patient charges were not consistently applied according to the approved sliding fee discount schedule.
  • Impacted Requirements: Compliance with Section 330(k)(3)(G) of the Public Health Service Act and Health Center Program guidelines.
  • Recommended Follow-up: Review and strengthen procedures to ensure accurate calculation and application of sliding fee discounts for all eligible patients.

Finding Text

Criteria – Section 330(k)(3)(G) of the Public Health Service Act and applicable Health Center Program requirements require health centers to maintain a sliding fee discount program under which patient charges are adjusted based on ability to pay. The Health Center Program Compliance Manual, Chapter 9 – Sliding Fee Discount Program, requires the Organization to maintain board-approved policies and an approved sliding fee discount schedule that is applied consistently based on patient income and family size. For patients with annual income at or below 100% of the applicable Federal Poverty Guidelines, the Organization must provide a full discount or, if established by the Organization, charge only a qualifying nominal amount. Patients with income above 100% and at or below 200% of the Federal Poverty Guidelines must receive partial discounts based on gradations in income and the Organization's approved sliding fee discount schedule. Condition and Description – During our testing of the Organization’s Sliding Fee Discount Program, we tested 15 patient encounters and identified two exceptions in which patient charges and related sliding fee adjustments were not applied in accordance with the Organization’s approved sliding fee discount schedule. These exceptions indicate that controls over the consistent application and calculation of sliding fee discounts were not operating effectively during the year. Cause/Effect –. The Organization's procedures were not sufficiently effective to ensure that patient charges and related sliding fee adjustments were consistently calculated and applied in accordance with the approved sliding fee discount schedule. As a result, certain patients were charged amounts that did not conform to the Organization's approved schedule, increasing the risk of noncompliance with Health Center Program requirements and inconsistent application of discounts to eligible patients.

Corrective Action Plan

Management acknowledges the finding. The Organization has made significant improvements to the administration and monitoring of its Sliding Fee Discount Program; however, management recognizes that continued improvement is necessary to ensure consistent application of the approved sliding fee discount schedule at the point of registration. The exceptions identified were associated with front-desk processing and occurred during a period that included onboarding and training of new staff. Since that time, the Organization has continued to update front-desk procedures, strengthen oversight, and provide additional education regarding eligibility documentation, income and family-size requirements, and proper application of the approved sliding fee discount schedule. The Chief Operating Officer and clinical management, in collaboration with the Revenue Cycle team, will continue to provide training and monitor front-desk processes to improve consistency and compliance. The Revenue Cycle team will also conduct ongoing reviews of sliding fee activity to identify errors, provide timely corrective education, and ensure that the Organization's Sliding Fee Discount Program is administered in accordance with board-approved policies and applicable Health Center Program requirements.

Categories

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Other Findings in this Audit

  • 1238716 2025-002
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
93.224 HEALTH CENTER PROGRAM $5.87M
93.898 CANCER PREVENTION AND CONTROL PROGRAMS FOR STATE, TERRITORIAL AND TRIBAL ORGANIZATIONS $87,135