Finding 1239643 (2026-001)

Federal Grant Award Identification: Award H80CS00817-25-00-24 Identification of Repeat Finding and Finding Reference Number: Repeat Finding, 2025-001 was a significant deficiency Criteria: Under Section 330 of the Public Health Service Act, health centers must prepare and apply a sliding fee discount schedule (SFDS) to ensure that amounts owed for health center services by eligible patients are adjusted (discounted) based on the patient's ability to pay. This requirement is intended to ensure access to care for underserved populations. Under 2 CFR 200.303 Internal Controls. Non-Federal entities must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Statement of Condition: During testing of 60 encounters, we identified 21 encounters that were not in compliance with the SFDS compliance requirements and indicates control deficiencies in the process to apply the SFDS, as follows: •15 encounters - No documentation was available to support income eligibility determinations. •6 encounters - Inconsistent information or data between EPIC (the medical billing records system) and the support provided by the patient. Cause / Context: The Organization has insufficient monitoring controls to ensure the sliding fee scale is properly and consistently applied, which is caused by training gaps and failure to perform periodic monitoring. Effect or Potential Effect: Patients may have been undercharged, or not assessed the required nominal fees. Inaccurate SFDS could result in noncompliance with HRSA grant requirements and the organization may not be able to demonstrate compliance during federal program monitoring. These control deficiencies increase the risk of undetected and uncorrected noncompliance with program compliance requirements. Questioned Costs: None Recommendation: We recommend that management develop and implement a plan to monitor sliding scale fees applied on an ongoing basis and retroactively, including sampling of encounters to ensure the sliding fee scale is applied correctly and annual refresher training for registration and billing personnel. This plan would also include retraining staff on the income eligibility procedures with an emphasis on the importance of the process to both the patient and health center. Views of Responsible Officials: Management concurs with this finding and will establish controls to ensure proper staff training and documentation of the sliding fee discounts.