Finding Text
Criteria: In accordance with OMB No. 0915-0193, the Uniform Data System (UDS) report is required to be
submitted for the Health Centers Cluster program annually on a calendar year basis.
In accordance with 42 CFR 56.303, health centers must have a schedule of fees or payments for the
provision of their health services consistent with locally prevailing rates or charges and designed to cover
their reasonable costs of operation. They are also required to have a corresponding schedule of
discounts applied and adjusted based on the patient’s ability to pay. The patient’s ability to pay is
determined based on the official poverty guidelines, as revised annually by U.S. Department of Health
and Human Services (HHS). The schedule of discounts must provide for a full discount to individuals and
families with annual incomes at or below those set forth in the most recent poverty income guidelines
(except that nominal fees for service may be collected from such individuals and families) and for no
discount to individuals and families with annual incomes greater than twice those set forth in such
Guidelines.
Condition: The Organization determines the amount of fees to be charged to the patients based on their
annual gross income and household size in conjunction with the sliding fee schedule. During our testing
of sliding fee discount, we noted the following:
One (1) out of 60 patients selected was given a sliding fee discount when the patient did not qualify
for any discount under the program, resulting in overstatement of the sliding fee discount by $289.
One (1) out of 60 selections were given a discount, however, the Organization did not retain
physical support for proof of income for the verification of the eligibility and appropriate sliding fee
scale, resulting in a possible overstatement of the sliding fee discount by $129.
Context: The audit findings represent a systematic problem, see condition above.
Questioned Costs: $418 of the $8,533 patient charges sampled.
Effect: Patients were improperly categorized on the Organization’s sliding fee scale and were given an
improper sliding fee discount.
Cause: The inaccuracies in the application of the sliding fee program discounts were due to human error
and inadequate oversight and review.
Recommendation: We recommend that the Organization’s procedures be strengthened to ensure
1) income is properly verified and adequately documented, and 2) the sliding fee discount is properly
determined and applied. The Organization should strengthen processes surrounding monitoring of the
program to ensure the Organization’s policies are consistently and properly applied.
Repeat finding: This is a similar repeat finding to last year’s audit #2023-002.
Views of responsible officials and planned corrective actions: The Organization will strengthen
procedures to ensure discounts for sliding fee is applied consistently and accurately. Immediately, the
Organization will conduct monthly application audits. An audit of 25 sliding fee application forms
completed in the month prior will be examined for accuracy, along with their supporting data. All
information from these applications will be cross-verified in NextGen. The results from the sliding fee
monthly audits will be monitored and reported quarterly at the Quality Assurance and Quality
Improvement meetings. The Organization will be implementing a workflow adjustment stating all Slide
applications will be noted in the system with a 30-day expiration deadline. This will ensure the staff will be
able to notify the patient they would need to begin the process over and present the supporting
documentation. Once the documentation is received the timeframe will extend to one year.
Furthermore, the Organization will continue the practice of conducting skills assessments at the start of
the year and once more in July. These assessments are crucial as they help pinpoint staff members who
might benefit from refresher training. Moreover, a meeting has been scheduled to finalize the days and
times for virtual sliding fee application training. This training, aimed at all staff who handle a sliding fee
form, will be spread out over four weeks, with one session per week lasting an hour.
Additionally, the Organization will introduce a sliding fee training video to the new employee orientation.
After completing their NextGen training, staff will receive this training video via email. Furthermore, this
video will also be sent to all health center leadership to be utilized at the health center level.