Finding Text
Finding #: 2022-005 Special Tests and Provisions – Noncompliance (not material to compliance requirement)
Identification of Federal Program and Award
Program title: U.S. Department of Health and Human Services (DHHS): Public Health Services Act, Title III, Section 330 (Health Center Cluster)
CFDA #: 93.224/93.527 Award #: 17H80CS00172 Program Year: 2022
Criteria
Pursuant to 42 CFR section 56.303(g)(2), health centers must make every reasonable effort, including the establishment of systems for eligibility determination, billing, and collection, to secure from patients, payments for services in accordance with the schedule of fees and discounts.
Condition
During our testing of special tests and provisions, we noted instances of noncompliance relating to the health center’s application of sliding fee discounts to patient charges; 4 out of 40 patient records sampled showed instances where patient charges were not appropriately adjusted to be consistent with the sliding fee discount schedule. Compliance testing was not able to be completed for 1 out of 40 patient records, as the sliding fee discount was applied to a patient visit for which the financial screening application process was not completed (no records of salary or family size were provided to support the scale rating, which also was not provided).
Cause
Personnel were not following CAMcare’s Financial Sliding Fee Scale Policies and Procedures, which comply with 42 CFR section 56.303(g)(2).
Effect
Possibility of draw down restriction being placed on Payment Management System (PMS) account or denial of future funding.
Questioned Costs
None
Perspective Information
We tested a statistically valid sample of 40 patient visits out of a total population of 250+ uncompensated care program visits and determined that the audit finding represented a systemic problem.
Repeat Finding
This finding is not a repeated finding.
Recommendation
We recommend that management review financial sliding fee scale policies and procedures in place and closely monitor the patient billing process to ensure CAMcare is in compliance with the compliance requirements of 42 CFR section 56.303(g)(2).
Views of Responsible Officials
Management recognizes the noncompliance; on November 29, 2023, CAMcare’s CEO, Jillian Hudspeth, and CFO, Christopher Bernardi, agreed with this finding, and explained that Management plans to offer additional training to the Financial Screening Department members and require the department manager to perform a periodic audit of applications.