Finding Text
SLIDING FEE DISCOUNT DOCUMENTATION.Type of Finding: (E) Significant Deficiency in Internal Control Over Compliance of Federal
Awards (F) Instance of noncompliance of Federal Awards
Federal Agency: US Department of Health and Human Services
Program Name: Health Centers Cluster
Compliance Requirement: Special Tests and Provisions: Sliding Fee Discounts
Questioned Costs: None
Assistance Listing Number: 93.224, 93.527
Statement of Condition
During our testing of compliance of federal awards, we noted income for 4 out of 30 patients was incorrectly entered into the system and the slide was improperly applied.
Criteria
Per the Uniform Guidance compliance supplement, “Review a sample of financial records for patients treated during the audit period to determine whether patient charges were appropriately adjusted based on income and family size by applying the health center’s sliding fee discount schedule. (Note: Auditors are not required to test any documentation used to establish or verify income).
Effect
Without ensuring a thorough examination of the patient's income information inputted into the system, there is high risk that MVCHS is applying an incorrect sliding fee discount for health center services provided to individuals and families.
Cause
In 2023, MVCHS experienced significant turnover at the Front Office, where patient registration is completed. Due to a lack of continuity in staffing, the processes for acquiring documentation related to Sliding Fee Discount Program were inconsistent. Staff turnover, coupled with shut down due to wildfires and flooding, as well as a national pandemic, caused havoc on operation. Recommendation
To ensure compliance with federal regulations, MVCHS should ensure that proper income documentation for the Sliding Fee Discount Program is collected regularly from patients and updated in accordance with the corresponding Policy. Training should be provided to staff members regarding the collection and recording of income information for the Sliding Fee Discount Program, and finance and billing staff should perform oversight.
Management Response
MVCHS recognizes that in 2023 income for 4 out of 30 patients was incorrectly entered into the system and the slide was improperly applied.
1.
MVCHS will also ensure that required income documents are obtained and that the correct income (s) are applied. MVCHS will also ensure that patients who are unable to provide written verification at the time of their first appointment will complete the self-declaration portion of the SFDP application.
2.
MVCHS will provide training to Front Office staff to ensure that income and family size are properly entered into the system and the Slide is properly applied. MVCHS will ensure that proper documentation is collected from patients and that accurate information is entered into the system, even during staff turnover. Finance/Billing staff will ensure oversite of documentation.
3.
MVCHS reached out to the New Mexico Primary Care Association and was provided training for the Front Office Staff regarding the Sliding Fee Discount Program process in April 2024.
DRAFT