Finding Text
Finding Number: 2022-001 Finding Type(s): Significant deficiency in internal control over compliance; Non compliance related to sliding fee discounts special tests and provisions compliance requirement Information on the Federal Program: Program Name: Health Center Program Cluster (AL 93.224 and 93.527) Grant Award: 5 H80CS10593-14 from May 1, 2021 - April 30, 2022 and 5 H80CS10593-15 from May 1, 2022 - April 30, 2023 Agency: U.S. Department of Health and Human Services, Health Resources and Services Administration (HRSA) Criteria: In accordance with Section 330(k)(3)(G) of the Public Health Service Act (42 U.S. Code ? 254b), as an FQHC, the Organization must have a sliding fee discount program in which the Organization?s fee schedule is discounted based on a patient?s ability to pay. Condition: The Organization has not applied sliding fee discounts to patient charges consistent with its sliding fee discount program. Through testing a statistically valid sample of transactions for the appropriate application of the Organization's sliding fee discount program to 25 individual patient balances, we noted two patients did not have a valid application in effect for the date of service tested, resulting in the ineligible patients receiving discounts of approximately $275 and $168, respectively. Cause: Due to HRSA reporting requirements on the annual Universal Data System (UDS) report for specific patient demographic information, including patient income and family size, the same reporting tool within the the Organization's electronic health records (EHR) is used to capture data for both UDS reporting and sliding fee discount program eligibility. Patients applying for the sliding fee discount program would have the box "self declared" checked, for self declared income and family size, which would then be verified through the formal sliding fee discount application process. Patient accounts with this box checked will be automatically adjusted for sliding fee discounts. Patients not applying for the sliding fee discount program will have the box "self declared - pending approval" checked, resulting in data accumulation only. For the two patients in our sample, the incorrect box was checked resulting in the sliding fee discount being applied to the patient balances without a valid sliding fee application. The Organization has implemented internal monitoring procedures which include the review of sliding fee applications, however the procedures are not currently designed to sample discounts provided to patients to help ensure patients receiving a sliding fee discount are eligible and have a valid sliding fee application in accordance with the Organization's sliding fee discount policy. Effect: The Organization may not be applying sliding fee discounts to patient charges consistent with its sliding fee discount program, resulting in patients not eligible to receive a discount being provided a discount. Questioned Costs: None Repeat Finding: No Recommendation: We recommend management provide training to individuals involved in the patient intake and billing processes specific to the patient income and family size entry process and to modify internal monitoring procedures to include an emphasis in the sampling discounts applied to patient balances. Views of a Responsible Official and Corrective Action Plan: Management agrees with the finding and has implemented additional training and will update monitoring procedures to increase compliance with program requirements.