Finding Text
Health Center Program Cluster – Assistance Listing Nos. 93.224 U.S Department of Health and Human Services Award No. 5 H80CS00717-24-07, February 1, 2025 – January 31, 2026 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 – Patients received sliding fee discounts that were inconsistent with the stated sliding fee discount categories under the Organization's policy. Cause – The Organization did not comply with their sliding fee policy. Effect or potential effect – Sliding fee discounts were given to patients that were inconsistent with the Organization’s sliding fee discount policy. Questioned Costs – None Context – A sample of 25 encounters were tested out of the total population of 98,089 encounters. The sampling methodology used is not and is not intended to be statistically valid. Two patients received a sliding fee adjustment that was inconsistent with the approved policy for the proper sliding fee adjustments based on their family size and household income documentation. Identification as a repeat finding, if applicable – No Recommendation – We recommend management continue to ensure all personnel understand the sliding fee scale policy and adhere to the requirements and guidelines set forth in the policy. Procedures should be implemented to ensure that eligible patients receive discounts in accordance with the sliding fee scale and the Health Center Program Compliance Manual. Views of Responsible Officials and Planned Corrective Actions – Planned corrective action 1. Correct the identified exceptions. By November 2026, designated staff under the CFO's oversight will review the two cited encounters against the board-approved sliding-fee policy and the discount schedule in effect on each service date, verify supporting records of household income and family size, and document the correct category and required account adjustments. Any patient credit or refund identified as due will be processed in accordance with approved billing and collections procedures. 2. Assess extent and system configuration. By December 2026, Finance will conduct a targeted retrospective review of at least 50 additional sliding-fee encounters across applicable service lines, locations, and discount categories. The review will compare documented income and family size with the assigned discount. EHR and billing-system discount tables, effective dates, and any manual override permissions will be checked against the board-approved schedules. Errors will be corrected, and the review will be expanded if a broader issue is identified. 3. Standardize eligibility verification. By December 2026, NHHC will issue a written step-by-step workflow that requires documentation of income, family size, eligibility determination, and application of the correct sliding fee tier before the adjustment is finalized. Manual adjustments or overrides will require a documented reason and supervisory authorization, with an audit trail retained. 4. Provide competency-based training. By January 2027, relevant front-desk, eligibility, registration, and billing personnel will be trained on the approved Sliding Fee Discount Program policy and on the use of the applicable schedule. Completion records and a brief competency validation will be retained. Any policy revisions will be submitted to the governing board for approval before implementation. 5. Monitor sustained adherence. During January and February 2027, Finance will review at least 25 newly processed sliding-fee encounters per month. Results will be reported to the CFO and CEO, with a goal of 100% agreement between documented eligibility and applied discounts. Any discrepancy will be promptly remediated, including additional staff coaching and further sampling until the control is operating effectively. Responsible contacts: Jason Wallace, Chief Executive Officer; Monica Lerma, Chief Financial Officer Anticipated completion: February 2027 Evidence of correction: Two-case correction log and account documentation; retrospective sampling results; approved policy and schedule; validated EHR/billing discount mapping; updated workflow; training and competency records; monthly quality-control samples; and documented supervisory follow-up.