Finding 1239163 (2025-002)

Health Center Program Cluster – Assistance Listing Numbers 93.224 and 93.527 U.S. Department of Health and Human Services Criteria or specific requirement – Special Tests and Provisions: Sliding Fee Discounts (42 USC 254(k)(3)(g); 42 CFR sections 51c.303(g); and 42 CFR sections 56.303 (f)) Condition – Sliding fee discounts applied to patient charges were inconsistent with the Organization’s sliding fee discount schedule. The Organization’s sliding fee discount policy is not compliant with the Health Center Program requirements for certain dental services, which are within the scope of the Health Center Program. Cause – The Organization did not comply with its sliding fee discount policy. The Organization has expanded dental services provided in recent years and failed to ensure its policy is compliant in its entirety. Effect or potential effect – Patients may receive sliding fee discounts that are inconsistent with the Organization's approved policy and/or applicable Health Center Program requirements. Questioned costs – None Context – A sample of 40 encounters out of 44,317 total encounters was tested. The sampling methodology used is not and is not intended to be statistically valid. Five patients received a sliding fee adjustment that was inconsistent with the approved policy for the proper sliding fee adjustments based on their income documentation. In addition, the Organization's approved sliding fee discount schedule for certain dental services was not fully compliant with Health Center Program requirements for patients at or below 100% of the Federal Poverty Guidelines. Identification as a repeat finding, if applicable – Yes, see finding 2024-002. Recommendation – The Organization should review the sliding fee discount policy and schedules to ensure compliance with the Health Center Program Compliance Manual for all services within the scope of the program. The Organization should also consider simplifying the methodology used to calculate sliding fee discounts and related system processes to promote consistent application of discounts and improve ongoing compliance. The Organization should also continue educating personnel on the sliding fee discount program and consider implementing internal audits of sliding fee discounts to monitor and identify specific areas for further improvements or training.