Finding Text
Federal Agency: Department of Health and Human ServicesFederal Program: Family Planning Services – Title XFederal Assistance Listing Number(s): 93.217 Award Period: July 1, 2022 to June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance Compliance – Other Matters Criteria or Specific Requirement: In accordance with the HHS Office of Population Affairs Title X Program Handbook, Chapter 3: Program Expectations, family planning service providers must prepare and apply a sliding fee discount schedule so that amounts owed for family planning services by eligible patients are adjusted based on the patients’ ability to pay. In accordance with 42 CFR 59.5(a), family planning service providers must have a schedule of fees or payments for the provision of their services consistent with locally prevailing rates or charges and designed to cover their reasonable costs of providing services. They are also required to have a corresponding schedule of discounts applied and adjusted based on the patient’s ability to pay. The patient’s ability to pay is determined based on the federal poverty guidelines, as revised annually by U.S. Department of Health and Human Services (HHS), which considers the patient’s annual income and household size. Condition: The Organization determines the sliding fee discount charged to the patients based on their annual gross income and household size. During our testing of patient files, we noted the 3 out of 40 encounters selected did not have a patient intake form on file that supported the patient’s annual income and household size that was entered into the patient billing system. Of those 3 encounters none of the patients were improperly charged or given a sliding fee discount, as their insurance provider covered the full cost of services in accordance with the program requirements. Context: Patient intake forms are signed by both the patient and clinic personnel. This form is filled out by the patient indicating use or no use of insurance, that they are responsible for the charges, etc. This form also serves as verification of the patient’s annual income and household size which is then entered into the patient billing system to calculate billing/ eligibility for assistance, as applicable. Cause: Due to the lack of retaining the intake forms the patient’s income and household size that was entered into the patient billing system could not be fully supported. This was caused by inadequate oversight and review. Effect: Patients could have been given an improper sliding fee discount without documentation to support that the patient qualified based on their income and household size. Recommendation: We recommend management review its patient intake process to ensure income and household size is properly verified, adequately documented, and retained for each patient in accordance with organizational policies and program requirements. Views of Responsible Official: Management agrees with the finding. Management will review its patient intake policies and procedures.