Finding Text
Health Center Program Cluster –
CFDA Nos. 93.224 and 93.527
U.S. Department of Health and Human Services
Award No. 2 H80CS00532-21-01 and 6 H80CS00532-22-08
Program Years 2021 and 2022
Criteria or Specific Requirement – Special Tests and Provisions: Sliding Fee Discounts (42 USC 254(k)(3)(g); 42 CFR sections 51c.303(g); and 42 CFR sections 56.303 (f))
Condition – Patients received a sliding fee discount that was inconsistent with the stated sliding fee discount categories under the Organization’s policy.
Questioned cost – None
Context – A sample of 25 patients were tested out of the total population of 42,708 encounters. The sampling methodology used is not and is not intended to be statistically valid. Two patients received a sliding fee adjustment that was inconsistent with the approved policy for the proper sliding fee adjustments based on their income documentation.
Effect – Sliding fee discounts were given to patients that were inconsistent with the Organization’s sliding fee discount policy.
Cause – The Organization did not comply with their sliding fee policy.
Identification as a repeat finding, if applicable –Is not a repeat finding.
Recommendation – We recommend management continue to ensure all personnel understand the sliding fee scale policy and adhere to the requirements and guidelines set forth in the policy. Procedures should be implemented to ensure that eligible patients receive discounts in accordance with the sliding fee scale and the Health Center Program Compliance Manual.
Views of Responsible Officials and Planned Corrective Actions – We are updating our policy and reviewing with staff. Updates include adding verbiage that nominal fees may be waived as a hardship adjustment (NOMWV), and that self-pay provider office visit charges will be reviewed case-by-case and adjusted as a self-pay/hardship discount.
We added the following adjustment codes:
o NOI No Income Adjustment - will use when patient has completed Statement of No Income.
o NOMWV Nominal Fee Waiver Adjustment - will use when patient cannot pay nominal fee. Reviewed case-by-case basis.
Billing ran reports for 2024 and will correct any Nominal Fee waivers, No Income Adjustments, or sliding fee office visit charges so that they align with this corrective action.
Everything will be put into place by September 30, 2024