Finding Text
Item 2023-001 - Implementation of Sliding Fee Scale Policy: U.S. Department of Health and Human Services, Health Center Program Cluster: Assistance Listing Number 93.224/93.527 - Special Tests and Provisions (Significant Deficiency)
Criteria:
US Code Title 42, The Public Health and Welfare Act, Section 254 b requires Health Centers to prepare and apply a sliding fee discount schedule so that the amounts owed for health center services by eligible patients are adjusted or discounted based on the patient's ability to pay. Community Health Project, Inc.'s policy requires that the board of directors and the Executive Director review the fee structure annually.
Statement of Condition:
During our audit of the year ended June 30, 2023, we noted that the board of directors did not review and approve the 2023 sliding fee scale.
Cause:
Due to transition in management, the review of the sliding fee scale was not included among the agenda items for the board meeting.
Effect:
Failure in implementing one of the internal control procedures over the sliding fee scale may lead to errors and non-compliance of the sliding fee scale to certain federal poverty guidelines.
Questioned costs:
None
Context:
The board did not review and approve the sliding fee scale before it was implemented in February 2023.
Identification as a repeat finding:
This is not a repeat finding.
Recommendation:
We recommend that management implement their policy that requires board review and approval of the sliding fee scale in a consistent manner. The approval of the sliding fee scale should be added to the agenda items as a recurring annual matter to help ensure that it is completed. We recommend further that the employee/s in charge of inputting the sliding fee scale into the electronic medical record ("EMR") system obtain evidence of board approval of the sliding fee scale before it is coded into the EMR.
Management response:
Management is in agreement with the audit finding that the sliding fee scale was not presented to the board of directors for review. However, the board reviewed the sliding fee scale during their meeting in February 2024 and did not find any error in the sliding fee scale and they retroactively approved and authorized its application from February 2023 to February 2024. Measures will be taken to ensure that the sliding fee scale is presented on a yearly basis to the board of directors for their review and that such review is documented.