Finding 369611 (2023-001)

Health Center Program Cluster; Federal Assistance Listing No. 93.224 and 93.527; HHS; grant number H80CS45850 and H8GCS48464; budget periods August 1, 2022, through July 31, 2023, and December 1, 2022, through December 31, 2023, respectively. Criteria or specific requirement: Special Tests and Provisions – 42 CFR, Part 56.303(e), (f) and (g). Health Centers receiving funds under the Health Center Program Cluster are required to prepare a schedule of fees or payments for the provision of its services designed to cover its reasonable costs of operation and a corresponding schedule of discounts adjusted on the basis of the patient’s ability to pay, to make every reasonable effort, including the establishment of systems for eligibility determination, billing and collection, and to secure from patient payments for services in accordance with the schedule of fees and discounts. Condition: We noted that the Health Center did not properly apply the sliding fee discounts approved by the board of directors for 12 patients out of a sample of 25 patients tested for the year ended June 30, 2023. Questioned cost: None Context: From a total of 829 sliding fee discounts for the period, 25 discounts were selected for testing. This sample was not, and was not intended to be, a statistically valid sample. The Health Center’s management did prepare a schedule of discounts adjusted on the basis of the patient’s ability to pay; such schedule was periodically updated and approved by the Health Center’s board of directors and the schedule was uploaded into the Health Center’s billing system. However, there were errors when comparing the approved schedule to certain actual adjustments to patient accounts during the year ended June 30, 2023. For 10 of the 12 errors, the patient was properly categorized in the correct sliding fee category based on supporting documentation; however, the system incorrectly posted contractual adjustments and, thus, caused errors in the sliding fee discount applied. This error also caused some instances in which the nominal fee was not charged correctly. One patient was included in the incorrect sliding fee category and one patient did not have a sliding fee application. Effect: Discounts were not properly applied to patient accounts. Cause: The Health Center did not comply with their sliding fee policy due to posting errors in the system, incorrect charges posted and lack of supporting documentation. Identification as a repeat finding, if applicable: Not a repeat finding. Recommendation: All personnel involved in the sliding fee discount program should demonstrate their understanding of the sliding fee scale policy in order to improve application of the sliding fee discount program. Views of responsible officials and planned corrective actions: The University agrees with the finding. See separate report for planned corrective action.