Finding 498513 (2023-001)

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 2023-001 - 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, 2023. 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, 2023. 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. Questioned Costs None Context While performing our audit, we noted that the Center did not properly determine the sliding fee discount category given to three out of twenty-four patients selected for testing based on the sliding fee scale in effect for the year ended December 31, 2023. For two of these patients, there was no supporting documentation on file to support the sliding fee discount provided. Identification as a Repeat Finding Condition is a repeat finding - see 2022-001. 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 As part of the corrective action plan for this finding, the Center hired a consulting firm in September 2023 to perform a comprehensive review of the Center's electronic medical record system to ensure that the system setup is correct and that proper reports are being generated. In addition, the consulting firm is training all front desk staff, including the director and supervisors and conducting bi-weekly audits to ensure that the staff is complying with the sliding fee scale program. Lastly, the Chief Compliance Officer will be conducting daily audits of transactions that occurred the previous business day to ensure compliance with the sliding fee program.