Finding Text
Federal Agency: U.S. Department of Health and Human Services
Federal Program: Consolidated Health Centers Grant
AL Number: 93.224 & 93.527
Award Period: 1/1/23 - 12/31/23
Type of Finding: Material Weakness in Internal Control Over Compliance and Compliance
Criteria or Specific Requirement
Per Title 42 Chapter 1 Subchapter D Section 51c303(f), “Health centers must have a schedule of fees or payments for the provision of their health services consistent with locally prevailing rates or charges designed to cover their reasonable costs of operation. They are also required to have a corresponding schedule of discounts applied and adjusted on the basis of the patient’s ability to pay.”
Condition and Context
During our testing of sixty sliding fee discounts for health center patients qualifying for reduced charge visits, we identified five visits where a slide was provided but there was no application on file to support the slide that was applied.
Effect
Potential that a patient would not receive the appropriate sliding fee discount.
Questioned Costs
None identified.
Cause
Clerical error in which the application was not scanned into the patients chart due to lack of an oversight process in place.
Recommendation
We recommend the Organization to review internal controls in regards to the determination, recording, and monitoring of the sliding fee process to ensure that appropriate sliding fee rates/categories are utilized for each sliding fee encounter. We also recommend the Organization put a process in place to make sure all applications are retained.
Section III – Findings and Questioned Costs – Major Federal Programs (Continued)
2023 – 001 Special Tests: Application of Sliding Fee Discount (Continued)
Views of Responsible Officials
The Organization made several changes at the end of 2023 to ensure we appropriate documentation in patient charts. The following is a summary of the changes:
• Hired a patient services manager to manage the front desk and call center in November 2023.
• Moved sliding fee application process to the front desk from enrollment, previously the applications were handed off for scanning. Now the front desk owns the entire process from getting the application from the patient to scanning it into the chart.
• We have implemented a monthly audit process to spot check applications for accuracy and ensure complete documentation in the chart.
• We also began using an app called Luma to help patients complete sliding fee electronically when a patient is comfortable. This eliminates the need to scan documents.