Finding Text
2023-001 Special Tests and Provisions - Sliding Fee Discounts
Program Information
Federal Agency U.S Department of Health and Human Services
Assistance Listing Numbers 93.224 & 93.527 Health Center Program Cluster
Award Numbers H80CS26602, H8FCS40619, H8DCS35705, H8GCS47935, H8ECS44806
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 audit we noted inadequate records to support the calculation of sliding fee discounts applied for 10 out of 25 patient encounters.
Context Certain records were not retained when the Organization converted to its new electronic health records (EHR) system. Patient reports from the prior EHR system were not available to provide the appropriate transaction-level detail.
Cause Records were not retained sufficient to calculate the sliding fee discount applied.
Effect Improper sliding fee discount could have been applied to a patient’s account.
Questioned Costs None identified.
Recommendation We recommend reporting capabilities be retained in the legacy system’s EHR or transferred to the new system’s EHR when system upgrades occur.
Views of responsible officials and planned corrective action During the conversion to the new EMR, patient medical record history and other documents were transferred to the new EMR, which included the sliding fee scale (SFS) applications. However, Management was unable to access the former EMR, eClinical Works (eCW), or download the details of the financial transactions showing the SFS discount was applied to the claim after the contract with eCW was terminated. Upon termination, eCW only offered reports of the financial transaction data, which Management provided to the auditors; however, this was not sufficient for demonstrating the discount on the claim as Management could not show the claim in eCW. Management will create a procedure for transferring major data systems, such as the EMR, to include transfer of appropriate financial transaction information and/or retention of access to the legacy system until all audit and record retention requirements are met. This procedure will be created by March 31, 2024.