Finding 386818 (2023-001)

2023 – 001 Federal agency: U.S. Department of Health and Human Services Federal program title: Health Center Program Cluster Assistance Listing Number: 93.224 and 93.527 Award Period: July 1, 2022 through June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance and Compliance Criteria or specific requirement: Special Tests and Provisions: Sliding Fee Discounts (42 USC 254(k)(3)(g); 42 CFR section 51c.303(g) and 42 CFR section 56.303(f)). Condition: Bullhook Community Health Center, Inc.’s (the Clinic) sliding fee discount program provides discounts to uninsured patients based on the patient’s income and poverty levels. During our audit we noted two instances where the Clinic was missing the supporting documentation used to determine a patient’s eligibility for a sliding fee discount. Under the Clinic’s policy, these documents should be maintained as part of the patient’s record. Questioned costs: None. Context: A sample of 25 encounters were tested in relation to the sliding fee discount program. Of the 25 encounters tested two of the selections did not have a sliding fee application retained in the patient record per the Clinic’s policy to document verification of a patient’s eligibility for the sliding fee discount. Cause: The Clinic did not maintain proper documentation of sliding fee eligibility. Effect: Improper sliding fee discounts could be given to patients. Repeat finding: No. Recommendation: Management should review their policies and procedures with the personnel responsible for providing the sliding fee discount and for ensuring that documentation is maintained to support the eligibility of sliding fee discount. We also recommend that management implement, monthly or quarterly, a self-audit process of newly approved sliding fee discount recipients and their associated patient record. Views of responsible officials: There is no disagreement with the audit finding.