Finding 1241591 (2025-002)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2025
Accepted
2026-11-03
Audit: 415633
Auditor: COHNREZNICK LLP

AI Summary

  • Core Issue: The Center failed to accurately determine sliding fee discounts for patients, violating federal guidelines.
  • Impacted Requirements: Compliance with the sliding fee scale based on patients' ability to pay, as mandated by federal poverty guidelines.
  • Recommended Follow-Up: Implement training for staff, establish supervisory reviews, and conduct regular internal audits to ensure proper application of sliding fee discounts.

Finding Text

Section III - Federal Award Findings and Questioned Costs Item 2025-002 - Special Tests and Provisions - U.S. Department of Health and Human Services, Health Center Program Cluster (Assistance Listing Number 93.224/93.527), FAIN # H8000410 and H8N53897, for FY 2025 - Material Weakness Criteria Health centers are required to have a corresponding schedule of discounts applied and adjusted on the basis of patients' ability to pay and their eligibility. A patient's eligibility to pay is determined on the basis of the official poverty guideline, as revised by DHHS (42 CFR Sections 51c, 107(b)(5), 56.108(b)(5) and 56.303(f)). The Center should be implementing and monitoring procedures to properly determine, calculate and review sliding fee discounts issued to patients in accordance with the Center's sliding fee scale. Statement of Condition While performing our audit, we noted that the Center did not properly determine the sliding fee discount category given to patients selected for testing based on the sliding fee scale in effect for the year ended December 31, 2025. Cause The condition can be attributed to human error and the lack of internal controls to review and ensure that the proper sliding fee documentation is being maintained and applied. Effect or Potential Effect The Center did not comply with the determination of sliding fee discounts based on the federal poverty guidelines in effect for the year ended December 31, 2025. In addition, the Center may not have properly calculated the sliding fee or discount given to the patients and the discount given, if any, may not have been based on the patient's ability to pay. Questioned Costs None Context While performing our audit, we noted that the Center did not properly determine the sliding fee discount category given to five out of 20 patients selected for testing based on the sliding fee scale in effect for the year ended December 31, 2025. Identification as a Repeat Finding This finding is a repeat finding - see 2024-001. Recommendation We recommend that proper training be given to employees at registration to ensure that the sliding fee discounts are monitored and reviewed by a supervisor on a periodic basis to ensure compliance with the sliding fee scale. In addition, management should conduct internal audits to ensure the sliding fee is calculated properly. Views of Responsible Official Management of the Organization agrees with the finding and has identified a need to strengthen the consistent application and documentation of the sliding fee discount program, including front-end staff processes related to patient eligibility, documentation, and collection of applicable fees, as well as back-end billing processes to ensure that sliding fee adjustments and write-offs are applied accurately and consistently. The Organization will implement a standardized training, monitoring, and reconciliation process to ensure appropriate administration of the sliding fee discount program from patient registration through final account reconciliation. All front desk/patient services staff will receive mandatory training on the sliding fee discount program.The billing/revenue cycle team will establish a back-end review process to ensure that accounts approved for the sliding fee discount program are adjusted appropriately. Furthermore, management will conduct routine audits of a sample of sliding fee discount program accounts to confirm compliance at both the front and back end. Audit findings will be reviewed with patient services and billing leadership, and any identified deficiencies will result in immediate correction and additional staff education as necessary. The Organization will monitor compliance on an ongoing basis to ensure that the corrective action is sustained and that eligible patients consistently receive the appropriate sliding fee discount.

Corrective Action Plan

CORRECTIVE ACTION PLAN September 25, 2026 Health Resources and Services Administration Brooklyn Plaza Medical Center, Inc. respectfully submits the following corrective action plan for the year ended December 31, 2025. CohnReznick LLP 1301 Avenue of the Americas New York, NY 10019 Audit Period: December 31, 2025 The findings from the December 31, 2025 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the number assigned in the schedule. FINDINGS – FEDERAL AWARDS PROGRAM AUDIT U.S. Department of Health and Human Services, Health Center Program Cluster (Assistance Listing Number 93.224/93.527) FAIN # H8000410 and H8N53897 for 2025 Finding 2025-002 – Special Tests and Provisions MATERIAL WEAKNESS Recommendation We recommend that proper training be given to employees at registration to ensure that the sliding fee discounts be monitored and reviewed by a supervisor on a periodic basis to ensure compliance with the sliding fee scale. In addition, management should conduct internal audits to ensure the sliding fee is calculated properly. Action Taken and Expected Date of Correction Identified Issue: Brooklyn Plaza Medical Center identified a need to strengthen the consistent application and documentation of the Sliding Fee Discount Program (SFDP), including front-end staff processes related to patient eligibility, documentation, and collection of applicable fees, as well as back-end billing processes to ensure that sliding fee adjustments and write-offs are applied accurately and consistently. Corrective Action Brooklyn Plaza Medical Center will implement a standardized training, monitoring, and reconciliation process to ensure appropriate administration of the Sliding Fee Discount Program from patient registration through final account reconciliation. This will be implemented by December 2026. Front Desk Training and Standardization All Front Desk/Patient Services staff will receive mandatory training on the Sliding Fee Discount Program. Training will include: • Reviewing the current Sliding Fee Discount Program policy and fee schedule. • Determining and documenting household size and income in accordance with established policy. • Identifying patients who may qualify for the Sliding Fee Discount Program. • Properly completing and maintaining required eligibility documentation. • Applying the appropriate sliding fee category based on established income guidelines. • Communicating the program and applicable patient responsibility clearly and consistently to patients. • Ensuring appropriate information is entered into the electronic health record/practice management system so that billing can process the account correctly. Training will be incorporated into the onboarding process for new Front Desk staff and reinforced through periodic refresher training. Billing and Write-Off Reconciliation The Billing/Revenue Cycle team will establish a back-end review process to ensure that accounts approved for the Sliding Fee Discount Program are adjusted appropriately. Billing staff will verify that: • The correct sliding fee category has been applied. • Patient responsibility is consistent with the approved sliding fee schedule. • Applicable contractual adjustments and sliding fee write-offs are accurately posted. • Sliding fee balances are not incorrectly transferred to patient responsibility or collection activity. • Any discrepancies identified between front-end documentation and back-end billing are corrected promptly. Billing will also conduct periodic reconciliation of sliding fee accounts to identify inappropriate balances, missed adjustments, or incorrect write-offs. Monitoring and Quality Assurance Management will conduct routine audits of a sample of Sliding Fee Discount Program accounts to confirm compliance at both the front and back end. Audit findings will be reviewed with Patient Services and Billing leadership, and any identified deficiencies will result in immediate correction and additional staff education as necessary. The organization will monitor compliance on an ongoing basis to ensure that the corrective action is sustained and that eligible patients consistently receive the appropriate sliding fee discount. Responsible Parties: Practice Administration/Patient Services Leadership Revenue Cycle/Billing Leadership Finance Compliance Expected Outcome: Brooklyn Plaza Medical Center will have a standardized and auditable process that ensures Sliding Fee Discount Program eligibility is appropriately determined and documented at the front end and that corresponding billing adjustments and write-offs are accurately reflected on the back end. If the Health Resources and Services Administration has questions regarding this plan, please call Philip J. Onorato, Chief Executive Officer at 718-596-9800, ext. 205.

Categories

Special Tests & Provisions Subrecipient Monitoring Eligibility Material Weakness Internal Control / Segregation of Duties

Other Findings in this Audit

  • 1241590 2025-002
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
93.224 HEALTH CENTER PROGRAM $4.46M
93.914 HIV EMERGENCY RELIEF PROJECT GRANTS $458,353
93.918 GRANTS TO PROVIDE OUTPATIENT EARLY INTERVENTION SERVICES WITH RESPECT TO HIV DISEASE $267,918
93.526 GRANTS FOR CAPITAL DEVELOPMENT IN HEALTH CENTERS $195,929
93.994 MATERNAL AND CHILD HEALTH SERVICES BLOCK GRANT TO THE STATES $57,560
93.527 GRANTS FOR NEW AND EXPANDED SERVICES UNDER THE HEALTH CENTER PROGRAM $14,310