Finding Text
2024-002 – Special Tests and Provisions
Federal Agency: U.S. Department of Health and Human Services (HHS)
Federal Program Name: Consolidated Health Centers (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, Public Housing Primary Care, and School Based Health Centers); (HHS Community Health Center Program)
Assistance Listing Number: 93.224/93.527
Award Period: Various award periods with the earliest period beginning April 1, 2022 and the latest ending August 31, 2025.
Type of Finding: Significant deficiency in internal control over compliance
Criteria or Specific Requirement: Health centers must prepare and apply a sliding fee discount schedule so that eligible patient balances are discounted based on the patient’s ability to pay.
Condition: The Association received a completed sliding fee application for a patient in our sample; however, the patient’s fee was not adjusted down for the sliding fee.
Questioned Costs: None
Context: The Association did not properly apply a sliding fee adjustment to 1 of 40 patients tested.
Cause: The Front Desk Staff did not properly mark the completed application as received in the Association’s billing system and apply the sliding fee. In addition, since the application was not noted as received the patient’s account was not being flagged in the finance team’s monthly reports that indicate an application is ready for finance to review and approve for sliding fee adjustment to be applied in their billing system.
Effect: A patient’s fee was not reduced by their sliding fee application amounts, based to their ability to pay and the Association’s sliding fee scale.
Repeat Finding: Yes – 2023-001
Recommendation: We recommend that management hold additional training for front desk staff regarding the collection and verification of patient information for each patient. We also recommend enhancing your sliding fee status feature in your billing system to be completed for all patients to identify if the patient is insured, an application is pending, an application was received, an application was approved by finance for adjustment, and if an application was waived, to enable better tracking of the eligibility of each patient. We also recommend reviewing outstanding patient balances over 180 days to determine if follow up with a patient is required to collect the outstanding balance or to see if something has been collected by the front desk but not communicated to the finance team.
Views of Responsible Officials: Management agrees with the recommendations identified above. During April 2025, NHA started a project to review Self Pay balances with service dates prior to January 1, 2025 to follow up on why the balance is still outstanding. This would have caught the error identified above. In addition to this project, they have held additional trainings for front desk staff and will continue to do so and will continue to improve their methods of tracking patient eligibility.