Finding 571538 (2024-002)

Federal Agency: U.S. Department of Health and Human Services Federal Program Title: Health Center Program Cluster Assistance Listing Numbers: 93.224 and 93.527 Federal Award Identification Number and Year: H80CS00109-22; H80CS00109-23 Award Period: May 1, 2023 – April 30, 2024; May 1, 2024 – April 30, 2025 Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance Criteria or specific requirement: Health centers must prepare and apply a sliding fee discount schedule so that the amounts owed for health center services by eligible patients are adjusted (discounted) based on the patient’s ability to pay (42 USC 254(k)(3)(G); 42 CFR sections 51c.303(f), and (g); and 42 CFR sections 56.303(f), and (g)). Condition: The Organization did not maintain documentation to show that patients had been evaluated for eligibility under its sliding fee scale policy and did not apply sliding fee adjustments consistent with the sliding fee scale assigned. Questioned costs: None. Context: • Nine (9) of sixty (60) encounters did not have family size and income documented within the billing system in order to assess sliding fee discount eligibility. Each of these encounters occurred prior to December 31, 2023. • Five (5) of sixty (60) encounters did not have family size and income documentation updated within a year of the patient visit date. Three (3) of these encounters occurred prior to December 31, 2023 and two (2) occurred subsequent to December 31, 2023. • Thirteen (13) of sixty (60) encounters received a sliding fee adjustment which was incorrect based on the sliding fee scale assigned. Seven (7) of these occurred prior to December 31, 2023 and six (6) occurred subsequent to December 31, 2023. Cause: This matter was identified during a prior audit and required the Organization to make an update to the electronic medical records software and process for obtaining the necessary sliding fee information. The Organization started its corrective action during fiscal year 2024 upon becoming aware of the matter. As a result of when this matter was first identified, corrective action was not able to occur prior to the start of the fiscal year ended June 30, 2024. Effect: Patients may not be assessed a correct sliding fee discount according to the Organization's sliding fee scale and their ability to pay. Repeat Finding: Yes, prior year finding 2023-002. Recommendation: Management should continue to provide training and education to front desk staff related to the process for collecting family size and income information, along with inputting it into the electronic medical records. We also recommend enhancing any current internal audits of patient visits to determine all required patient information has been obtained in accordance with TCA’s policies. Views of responsible officials: There is no disagreement with this finding.