Finding 1240849 (2024-002)

Material Weakness Repeat Finding
Requirement
P
Questioned Costs
-
Year
2024
Accepted
2026-10-21
Audit: 415177
Organization: State of Kosrae (FM)
Auditor: BCM LLC

AI Summary

  • Core Issue: The Wa’ab Community Health Center failed to properly assess and document patient income and family size for sliding fee discounts, continuing a significant deficiency from the previous year.
  • Impacted Requirements: Compliance with federal regulations under the Health Center Program requires accurate application of sliding fee discounts based on individual assessments, which were not conducted.
  • Recommended Follow-Up: YSG should collaborate with the health center to implement procedures for timely submission of patient financial records and develop a comprehensive Sliding Fee Discount Schedule to ensure compliance.

Finding Text

Federal Program: Health Center Program Cluster Assistance Listings: 93.224 and 93.527 Federal Agency: U.S. Department of Health and Human Services Compliance Requirement: Special Tests and Provisions – Sliding Fee Discounts Type of Finding: Significant Deficiency in Internal Control over Compliance and Noncompliance Criteria: Under the Health Center Program Cluster (ALN 93.224 and ALN 93.527), as governed by Section 330(k)(3)(G) of the Public Health Service Act and 42 CFR 51c.303(f), (g), and (u), health centers are required to implement and apply a sliding fee discount schedule (SFDS) to adjust patient charges based on income and family size, ensuring access to affordable healthcare services for low-income individuals. The sliding fee discounts must be applied in accordance with the health center’s approved schedule. Condition: This finding was reported in the prior year, and the condition continued during the fiscal year ended September 30, 2024. In performing our audit procedures at the Wa’ab Community Health Center, we noted that income and family-size assessments were not performed or documented for patients as required by the Health Center Program. The health center treated the entire Yap State population as being below the applicable federal poverty level, resulting in patients automatically qualifying for sliding-fee discounts without documented individual assessments. The documentation provided by Yap State Government and the health center was limited to cash receipts reports. These reports did not contain sufficient patient-level information regarding income and family size to allow us to determine whether patients were assigned to the appropriate sliding-fee discount category and whether discounts were calculated and applied in accordance with program requirements. On April 10, 2026, the Wa’ab Community Health Center issued a policy stating that no patient will be denied health care services because of the individual’s inability to pay. Although this policy addresses the requirement to provide services regardless of a patient’s ability to pay, it does not eliminate the separate requirement to assess patients for sliding-fee discount eligibility based on income and family size. The policy also does not demonstrate compliance during the fiscal year ended September 30, 2024. Accordingly, the April 10, 2026 policy does not resolve the condition identified in the current-year or prior-year finding. Cause: The health center did not establish or consistently implement procedures requiring patient income and family size to be assessed, documented, and periodically reassessed for purposes of determining eligibility under the sliding fee discount program. The health center also did not maintain or provide patient financial records necessary to demonstrate that discounts were properly determined and applied. Effect: We were unable to determine whether the health center properly assessed patient eligibility or applied sliding-fee discounts in accordance with Health Center Program requirements. The condition increases the risk that patients may be assigned to incorrect discount categories and that patient charges may not be calculated consistently or accurately. Questioned Costs: None Recommendation: We recommend that YSG work closely with the health center to establish and enforce procedures for the timely and complete submission of patient financial records for audit and compliance purposes. The health center should ensure that adequate documentation is maintained to support income and family size determinations and the proper application of sliding fee discounts. If necessary, YSG should seek guidance from the federal awarding agency to ensure compliance with program requirements. In addition, Yap State Government health centers should immediately develop, implement, and document a comprehensive Sliding Fee Discount Schedule in accordance with applicable federal regulations. Identification as a Repeat Finding: Yes – Finding 2023-002 Views of Responsible Officials: See the corrective action plan.

Corrective Action Plan

We agree with this Finding. We have updated our Sliding fee scale using the US Federal poverty guideline for year 2026, it has been approved by our board of directors as of 04/10/26. This new sliding fee scale is applied in the new ECW Electronic Health Records system that we are currently in the process of completing and instituting into our health centers. This new system is presumed to go live in September 2026 and will be able to accommodate our need to capture accurate demographic data that is needed to determine whether a patient is eligible for the discount or not, it will be able to automatically place each individual patient under the different sliding fee scale categories that they fall under based on their income once they register to see a doctor. So to correct our finding for 2023 and 2024, this is what we have been working on to improve our health center and build a system in place that will be able to capture the data we need, we will also be updating our sliding fee scale in the system every year based on the yearly US federal poverty guideline.

Categories

Special Tests & Provisions Eligibility Significant Deficiency Internal Control / Segregation of Duties

Other Findings in this Audit

  • 1240850 2024-003
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
15.875 ECONOMIC, SOCIAL, AND POLITICAL DEVELOPMENT OF THE TERRITORIES $23.28M
93.224 HEALTH CENTER PROGRAM $2.16M
84.027 SPECIAL EDUCATION GRANTS TO STATES $523,863
10.664 COOPERATIVE FORESTRY ASSISTANCE $140,695
93.268 IMMUNIZATION COOPERATIVE AGREEMENTS $129,886
93.959 BLOCK GRANTS FOR PREVENTION AND TREATMENT OF SUBSTANCE ABUSE $83,371
93.116 PROJECT GRANTS AND COOPERATIVE AGREEMENTS FOR TUBERCULOSIS CONTROL PROGRAMS $54,567
59.006 8(A) BUSINESS DEVELOPMENT PROGRAM $52,334
93.898 CANCER PREVENTION AND CONTROL PROGRAMS FOR STATE, TERRITORIAL AND TRIBAL ORGANIZATIONS $51,853
93.994 MATERNAL AND CHILD HEALTH SERVICES BLOCK GRANT TO THE STATES $50,655
15.904 HISTORIC PRESERVATION FUND GRANTS-IN-AID $41,434
93.527 GRANTS FOR NEW AND EXPANDED SERVICES UNDER THE HEALTH CENTER PROGRAM $40,236
93.092 AFFORDABLE CARE ACT (ACA) PERSONAL RESPONSIBILITY EDUCATION PROGRAM $35,465
93.377 PREVENTION AND CONTROL OF CHRONIC DISEASE AND ASSOCIATED RISK FACTORS IN THE U.S. AFFILIATED PACIFIC ISLANDS, U.S. VIRGIN ISLANDS, AND P. R. $26,790
93.958 BLOCK GRANTS FOR COMMUNITY MENTAL HEALTH SERVICES $24,304
93.110 SPECIAL PROJECTS OF REGIONAL AND NATIONAL SIGNIFICANCE $23,381
93.217 FAMILY PLANNING SERVICES $16,121
93.104 COMPREHENSIVE COMMUNITY MENTAL HEALTH SERVICES FOR CHILDREN WITH SERIOUS EMOTIONAL DISTURBANCES (SED) $5,959
93.069 PUBLIC HEALTH EMERGENCY PREPAREDNESS $3,495
93.788 OPIOID STR $3,020
93.889 NATIONAL BIOTERRORISM HOSPITAL PREPAREDNESS PROGRAM $-910