Finding Text
2022 – 002 Special Tests: Application of Sliding Fee Discount
Federal Agency: U.S. Department of Health and Human Services
Federal Program: COVID-19: FY 2020 Health Center Program Look-Alikes: Expanding Capacity for Coronavirus Testing and COVID-19: American Rescue Plan Act Funding for Look-Alikes
AL Number: 93.224 & 93.527
Award Period: 7/1/21 - 6/30/22
Type of Finding: Material Weakness in Internal Control over Compliance and Compliance
Criteria or Specific Requirement
Per Title 42 Chapter 1 Subchapter D Section 51c303(f), “Health centers must have a schedule of fees or payments for the provision of their health services consistent with locally prevailing rates or charges designed to cover their reasonable costs of operation. They are also required to have a corresponding schedule of discounts applied and adjusted on the basis of the patient’s ability to pay.”
Condition and Context
During our testing of forty sliding fee discounts for health center patients qualifying for reduced charge visits, we identified three visits that received the incorrect sliding fee discount or that the sliding fee application could not be located.
Effect
Potential that a patient would not receive the appropriate sliding fee discount.
Questioned Costs
None identified.
Cause
Clerical error in which the incorrect discount was applied due to lack of an oversight process in place.
Recommendation
We recommend the Organization to review internal controls in regards to the determination, recording, and monitoring of the sliding fee process to ensure that appropriate sliding fee rates/categories are utilized for each sliding fee encounter.
Views of Responsible Officials
The Organization will review our procedures for ensuring that sliding fee applications are completed accurately and are properly placed in patient files. We will also research and implement safeguards to ensure that the revised procedures are being followed throughout the year, potentially including audits and additional staff training. This will be performed by Andrea Cortez, Chief Operating Officer, Karina Villagrana, Practice Manager, and Andrew Shahidi, Chief Financial Officer in the next 45 days. If during this process we determine that an update, revision, or re-write of the current Sliding Fee Policy is required, we will do so and it will be submitted to the Board of Directors for approval at the March 27, 2024 meeting.