Finding Text
2021-007—Special Tests and Provisions—Sliding Fee Discount Program
Federal program information:
Funding agency: U.S. Department of Health and Human Services
Title: Health Center Cluster
Assistance Listing Number (ALN): 93.224, 93.527
Award number and year: H80C00202 (1/1/2021–12/31/2021)
H8DCS36371 (4/1/2020–3/31/2021)
H8ECS37778 (5/1/2020–4/30/2021)
H8F40603 (4/1/2021–3/31/2023)
Criteria: According to 42 CFR Part 51c.303(f) and FCCH’s Sliding Fee Discount and Related Billing and Collections Program Policies and Procedures, a community health center must have prepared a schedule of fees or payments for the provision of its services designed to cover its reasonable costs of operation and a corresponding schedule of discounts adjusted on the basis of the patient's ability to pay, provided that such schedule of discounts shall provide for a full discount to individuals and families with annual incomes at or below those set forth in the poverty guidelines updated periodically in the Federal Register by the U.S. Department of Health and Human Services under the authority of 42 U.S.C. 9902(2); and for no discount to individuals and families with annual incomes greater than twice those set forth in such guidelines.
Condition: For two of 40 medical claims tested, the amount billed did not agree to FCCH’s fee schedule for the procedures performed during the clinic visit. One claim was billed to a third-party payer, and one claim was billed to the patient under FCCH’s sliding fee discount program (SFDP).
Questioned Costs: None
Context: Two of 40 medical claims tested.
Cause: FCCH experienced significant turnover in key positions in the billing department, including the Revenue Cycle Manager, and approved policies and procedures were not followed.
Effect: FCCH is not in compliance with 42 CFR Part 51c.303(f). Additionally, FCCH is not in compliance with its Sliding Fee Discount and Related Billing and Collections Program Policies and Procedures.
Auditor’s Recommendations: FCCH should implement its established policies and procedures which require adherence to the approved schedule of fees for services and discounts. FCCH should also consider performing its own review of medical claims billed to determine the prevalence of these errors.
Management’s Response: FCCH Management shall ensure adherence to established policies and procedures. Charges shall follow the schedule of fees and services, and discount programs shall be administered accurately so that compliance with 42 CFR Part 51c.303(f) and Sliding Fee Discount policies are maintained. FCCH shall also perform a review of its medical claims billed, determine the prevalence of errors, and educate staff to improve accuracy.