Finding Text
Assistance Listing Number: 93.224
Assistance Listing Program Title: Health Center Program Cluster
Federal Agency: U.S. Department of Health and Human Services (HHS)
Health Resources and Services Administration
Passed Through Entity: Not applicable
Federal Award Number: H80CS06647
Federal Award Year: January 1, 2023 to December 31, 2023
Compliance Requirement: Special Tests and Provisions – Sliding Fee Discounts
Criteria or Specific Requirements
Health centers must have a schedule of fees or payments for the provision of their health services
consistent with locally prevailing rates or charges and designed to cover their reasonable costs of
operation. 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 official
poverty guidelines, as revised annually by the U.S. Department of Health and Human Services (HHS).
The poverty guidelines are issued each year in the Federal Register and HHS maintains a web page
that provides the poverty guidelines.
Non-grant funds (State, local, and other operational funding and fees, premiums, and third-party
reimbursements which the project may reasonably be expected to receive, including any such funds
in excess of those originally expected), shall be used as permitted under the law and may be used for
such other purposes as are not specifically prohibited under the law if such use furthers the objectives
of the project.
Condition
El Proyecto determines the amount of fees to be charged to a patient based on the patient’s income,
expenses and number of dependents in conjunction with the sliding fee schedule.
In performing testwork, we noted that 1 out of 25 sampled patients was charged an incorrect sliding
fee amount resulting in El Proyecto undercharging the patient by a total of $70. This error was due to
oversight by the staff in the patient’s income amount used to calculate the sliding fee. Rather than
using gross income from the annual income tax return of the patient, taxable income was incorrectly
used to determine the sliding fee amount.
Questioned Costs
The total net amount undercharged was $70 for one patient sample.
Cause
The potential causes for the above error are as follows:
The staff normally uses a paystub as a source document to determine the patient’s income;
The staff requires additional training on using tax returns to determine patient’s income.
Effect
Errors in the determination of patient fee amounts could result in overcharging or undercharging of
fees, and noncompliance with federal requirements.
Recommendation
We recommend that El Proyecto’s controls and procedures be strengthened to ensure 1) income
declaration is properly verified and adequately documented and 2) that the sliding fee discount is
properly determined and applied. This should include incorporating additional procedures, as
necessary, in the existing checklist used to determine the patient’s sliding fee amount. El Proyecto
should also provide additional training to staff involved in the sliding fee process and ensure that
appropriate individuals are properly monitoring and reviewing El Proyecto’s compliance with program
requirements. This will help ensure that the proper sliding fee is charged to patients and that program
goals and objectives are being met.
Views of Responsible Officials and Planned Corrective Actions
El Proyecto will continue to implement the following measures to ensure compliance with the sliding
fee discount program, and consistently assess patient income and family size.
El Proyecto will continue to provide ongoing training to clinic staff who evaluate the sliding fee
application at its clinic locations. The training will consist of reviewing sliding fee program policies and
procedures along with all applicable patient forms, sliding fee scale, and patient eligibility.
Person Responsible: Leticia Vasquez
Position of Responsible Party: Billing Manager
Completion Date: September 30, 2024
B. Lack of Formal Review of the Quarterly General Ledger Reconciliation Reports by
Authorized Personnel
Criteria
In accordance with FMD Directive No. 17–002, El Proyecto must submit to the City the quarterly
General Ledger Reconciliation Report by the end of the month following each quarter. A template form
provided by the City includes a preparer and reviewer section.
In accordance with El Proyecto’s formal policies and procedures, quarterly and monthly reports must
be reviewed and approved by one of the following individuals:
Haimanot Fekado, Program Director
Mary Hernandez, Chief Operating Officer
Corinne Sanchez, Chief Executive Officer
Condition
In performing reporting compliance testwork, of the four (4) quarterly General Ledger Reconciliation
Reports selected for testwork, we noted that all four (4) were not properly signed as reviewed and
approved by one of the authorized personnel listed above, as follows:
Cause
El Proyecto does not have adequate monitoring controls in place to ensure that reports submitted are
properly reviewed and approved by authorized personnel.
Effect
Lack of formal review and approval may result in errors not being identified and corrected prior to
submission to the City.
Questioned Costs
Not applicable.
Recommendation
We recommend that El Proyecto strengthen its monitoring controls to ensure that formal policies and
procedures for the review and approval of reports are properly adhered to.
Views of Responsible Officials and Planned Corrective Actions
El Proyecto will implement monitoring measures to ensure that only authorized personnel can review
and submit reports. This also includes signing off on all needed contracts.
Person Responsible: Yulin Lin
Position of Responsible Party: Controller
Completion Date: September 30, 2024