Current Year Findings
Corrective Action Plan
2023-001 Improper application of sliding fee discount
CFDA Nos. – 93.224 and 93.527
Federal Award ID # and Year – 5 H80CS00744-21-00 Program Year 2023
Federal Agency Name: U.S. Department of Health and Human Services
Type of finding
Significant deficiency in internal control over compliance (recurring)
Criteria or Specific Requirement
Special Tests and Provisions: Sliding Fee Discounts per Title 42 Chapter 1 Subchapter D Section 51c303(f)
Condition
The Organization’s sliding fee program provides discounts on patient services based upon the
individual’s level of income. However, the Organization applied the incorrect discount based upon the
individual’s income per the Organizations sliding fee discount policy.
Cause
Clerical error in applying the sliding fee discount adjustment in the billing system for the patient.
Effect or Potential Effect
Improper sliding fee discounts given to patients.
Questioned Costs
None
Context or Perspective Information
A sample of 40 patients were tested out of the total population of 2,283 encounters. The sampling
methodology used is not statistically valid. Two patients received the incorrect sliding fee discount based
upon their income level.
Recommendation
We recommend that the Organization implement a verification process to ensure the sliding fee discounts
being applied are in accordance with their sliding fee policy.
Corrective Action Plan
Hidalgo Medical Services (HMS) will implement an enhanced training program to ensure the sliding fee
discounts are applied in accordance with the current sliding fee policy. A comprehensive re-training of
current Patient Financial Services (PFS) Claims Reviewing staff will occur by December 2023. A training
manual will be developed to include competency validation for each Claims Reviewer staff person,
and the new training model will be used for all future Claims Reviewer staff. In addition, HMS will
continue to use the training manual for all incoming Community Health Workers to ensure the sliding fee
assessment continues to stay in compliance.
35
Main Clinic & Administration
P.O. Box 550
530 DeMoss Street
Lordsburg, NM 88045
Secondly, HMS will implement an enhanced training program and verification process to ensure the
sliding fee discounts are applied in accordance with the current sliding fee policy. The Claims Reviewer
Supervisor will randomly select at least 30% of SFS patient visits monthly to ensure billing adjustment
accuracy. HMS has been working diligently over the last year to improve the sliding fee assessments,
and all proper documentation has been obtained (the new auditing requirement will occur
immediately). There were no findings this year on assessments, and we will apply a similar audit process
and follow-up action plan to the billing adjustment process. Also, all errors found will be fixed right away.
The Claims Reviewer Supervisor will report each month to the Chief Operating Officer (COO) the audit
results, and the COO will report to the Chief Executive Officer (CEO) any findings and required
corrections, if applicable. In addition, the Finance Director will continue randomly auditing the sliding
fee assessments each month to ensure compliance with the program. The Chief Financial Officer will
report each month to the CEO any findings and required correction, if applicable.
Person Responsible: Sonia Jacquez, Claims Reviewer Supervisor, Teresa Carrasco, Patient Specialist
Services Director, Amanda Frost, Chief Operating Officer, Jamie McMahen, Finance Director, and
Gretchen Cannon, Chief Financial Officer.
Anticipated Completion Date: December 31, 2023.