Finding Text
2023-002 Special Tests and Provisions
Program Information
Federal Organization U.S Department of Health and Human Services
Assistance Listing Numbers 93.224 & 93.527 Health Center Program Cluster
Award Numbers H80CS26623, H8FCS41667, H8DCS35811, H8HCS45016, H8GCS48510, C14CS39779
Criteria OMB 2 CFR 200, Subpart F Compliance Supplement, Part 4, Compliance Requirement N, Special Tests and Provisions states, “Health Centers must prepare and apply a sliding fee discount schedule so that the amounts owed for health center services by eligible patients are adjusted (discounted) based on the patients ability to pay.”
[X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness
Condition During our testing of sliding fee discounts for health center patients qualifying for reduced charge visits, we identified several incidents in which the sliding fee applied was not consistent with the entities policies based on the patient’s level of income.
Context This finding appears to be a systemic problem. A sample size of 25 patients included 15 who did not have the correct sliding fee applied. In addition, 3 of the 15 misapplied sliding fees were due to lack of application on file or incomplete application and 8 of the 15 misapplied sliding fees were due to the sliding fees scales not being correctly calculated by the billing software after changes to the scale were made.
Cause Due to turnover in the billing and admitting staff, there was lack of appropriate training relating to the requirements of the sliding fee system to properly administer the sliding fee program. In addition, the billing software was not properly updated for changes in the sliding fee scale to apply the sliding fees correctly based on the levels supported by the patient applications.
Effect Patients may have been granted the incorrect sliding fee adjustment.
Questioned Costs None identified.
Recommendation We recommend continued effort in training personnel on applying the appropriate sliding fee discount based on the Organization’s approved policy and in compliance with the OMB Compliance Supplement requirements. An appropriate level of review should be conducted on patient accounts to ensure proper document retention, application of sliding fee discounts, and third-party insurance billing. In addition, we recommend that after sliding fee scales are updated sufficient testing of billing software is performed to ensure that sliding fees scales are being properly applied.
Views of responsible officials and planned corrective action Management …