Finding 526487 (2024-001)

Finding 2024-001 – Sliding Fee Determination and Related Patient Billing U.S. Department of Health and Human Services Assistance Listing No. 93.224/93.527, Health Center Program Cluster Criteria: All section 330-funded health centers must prepare and apply a sliding fee discount schedule (SFDS), which adjusts amounts owed for health center services by eligible patients based on the patient’s ability to pay. Management is responsible to make sure controls are in place for patients to be charged in accordance with the SFDS and that income verifications are performed at least annually. Condition: As part of our compliance testing procedures for the HRSA 330 grant programs, we tested sixty patients billed under a sliding fee discount schedule. Of the patients tested, four patients (7%) were found to have exceptions as the income verification was either not performed or had not been performed within the past 12 months. Cause: Based on audit procedures performed, the income verification process was never performed or not performed on an annual basis for patients to be charged the correct amount for their service. Effect: The lack of controls and processes over the income verification process could cause revenue to be over or understated. The impact of the four patients that did not have appropriate documentation is not able to be quantified. Questioned costs: None. Repeat finding: Repeat of finding 2023-002. Recommendations: The established policies and controls did not operate effectively in these instances. Management should ensure processes are in place to make sure the income verification process is being performed annually for each patient. Views of responsible officials and corrective action plan: Although this was identified as a material weakness for FY ’23 and FY’24, training programs and staff education were not implemented until well into FY ’24. Training has and will continue to occur in the future through documented Front Desk Training sessions. Accountability measures have been implemented for staff who do not provide sufficient documentation for sliding fee as well as other patient visit requirements. For FY ‘25, RHC has already implemented a process whereby each quarter every patient is identified as a participant in sliding fee. Those participants are distributed to the general managers of each center who affirm the correct information has been obtained or, if not, the patient is removed from sliding fee participation and charges are reflected accordingly.