Finding 44578 (2022-001)

Section III - Federal Award Findings and Questioned Costs U.S. Department of Health and Human Services, COVID-19 Health Center Program Cluster (Assistance Listing Number 93.224/93.527) Item 2022-001 - Special Tests and Provisions Criteria Health centers are required to have a corresponding schedule of discounts applied and adjusted on the basis of patients' ability to pay and their eligibility. A patient's eligibility to pay is determined on the basis of the official poverty guideline, as revised by DHHS (42 CFR Sections 51c, 107(b)(5), 56.108(b)(5) and 56.303(f)). The Center should be implementing and monitoring procedures to properly determine, calculate and review sliding fee discounts issued to patients in accordance with the Center's sliding fee scale. Statement of Condition While performing our audit, we noted that the Center did not properly determine the sliding fee discount category given to patients selected for testing based on the sliding fee scale in effect for the year ended December 31, 2022. Questioned Costs None Context While performing our audit, we noted that the Center did not properly determine the sliding fee discount category given to four out of eleven patients selected for testing based on the sliding fee scale in effect for the year ended December 31, 2022. For one of these patients, there was no supporting documentation on file to support the sliding fee discount provided. Cause The condition can be attributed to human error and the lack of internal controls to review and ensure that the proper sliding fee documentation is being maintained and applied. Effect The Center did not comply with the determination of sliding fee discounts based on the federal poverty guidelines in effect for the year ended December 31, 2022. In addition, the Center may not have properly calculated the sliding fee or discount given to the patients and the discount given, if any, may not have been based on the patient's ability to pay. Identification as a Repeat Finding Condition is a repeat finding - see 2021-001. Recommendation We recommend that proper training be given to employees at registration to ensure that the sliding fee discounts are monitored and reviewed by a supervisor on a periodic basis to ensure compliance with the sliding fee scale. In addition, management should conduct internal audits to ensure the sliding fee is calculated properly. Views of Responsible Official The Center concurs with this finding and will ensure that additional controls will be put in place to timely detect systems and human errors in the sliding fee discount calculation. The Center will strengthen its monthly internal audits to monitor compliance with the sliding fee discount policies and procedures. The Center has also hired a consulting firm to do a comprehensive review of the electronic medical record system and help train the front desk staff, including the director and supervisor. The consulting firm will also conduct bi-weekly audits for six months to ensure the issue is resolved.