Finding Text
Information on the federal program – Assistance Listing Number 93.224/93.527,
Health Center Program Cluster from the U.S. Department of Health and Human
Services, Federal Award No. 6 H80CS28202-09 for project period February 1, 2022
through January 31, 2025
Criteria or specific requirement – Special Tests and Provisions – 42 CFR, Part
56.303(e), (f), and (g). Health Centers receiving funds under the Health Center
Program Cluster are required to prepare a schedule of fees or payments for the
provision of its services designed to cover its reasonable costs of operation and a
corresponding schedule of discounts adjusted on the basis of the patient’s ability to
pay, to make every reasonable effort, including the establishment of systems for
eligibility determination, billing and collection, and to secure from patient payments
for services in accordance with the schedule of fees and discounts
Condition – We noted during our testing of compliance with federal awards that
the Health Center did not properly apply the sliding fee discounts approved by the
board of directors for 4 out of a sample of 25 patients for the year ended December
31, 2024.
Cause – Errors occurred when analyzing the patient account
Effect or Potential Effect – Discounts were not properly applied to patient
accounts based on the policy.
Questioned Costs – Not applicable
Context – From a total of 16,857 sliding fee discounts for the period, 25 discounts
were selected for testing. This sample was not, and was not intended to be, a
statistically valid sample. The Health Center’s management did prepare a schedule
of discounts adjusted on the basis of the patient’s ability to pay; such schedule was
periodically updated and approved by the Health Center’s board of directors and
the schedule was uploaded into the Health Center’s billing system. However, there
were errors when comparing the approved schedule to certain actual adjustments
to patient accounts during the year ended December 31, 2024. For 1 of the 25
accounts selected for testing, the account had an incorrect discount applied and the
3 patients did not have supporting documentation (school based lunch application)
to support the slide applied.
Identification as a repeat finding, if applicable – Not a repeat finding
Recommendation – We recommend management work to provide additional trainings to the staff responsible for completing sliding fee applications and those responsible for applying the sliding fee discount to patient
accounts and conduct additional internal reviews to verify the patient accounts have
been adjusted properly and appropriate supporting documentation is maintained in
the patient’s file.
Views of responsible officials and planned corrective actions – Management
has begun staff training and will meet with the billing team regarding the sliding fee
policy and process.