Finding Text
Finding 2022-002 Application of Sliding Fee Discount Program Information: Federal Agency: U.S. Department of Health and Human Services Federal Assistance Listing Number: 93.224 and 93.527 Health Center Program Cluster Award Number: H80CS40219 Criteria: [X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness OMB 2 CFR 200, Subpart F Compliance Supplement, Part 4, Compliance Requirement N, Special Tests and Provisions states, ?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.? Condition: In our testing of 40 sliding fee discounts for health center patients qualifying for reduced charge visits, we identified 3 instances where no application was maintained. We also identified 2 instances where the incorrect sliding fee was applied to the patient. Cause: The Center did not have a review process in place to verify eligible patients completed the required application to receive a sliding fee discount and that each application contained the required information. Additionally, the Center did not verify the correct sliding fee discount was based on the Center?s sliding fee scale. Context: The finding appears to be a systemic problem. Effect: Missing applications could indicate that patients who received a sliding fee discount may not have been eligible. Additionally, the sliding fee discount could be applied incorrectly and not in accordance with the Center?s policy. Recommendation: We recommend developing proper controls around obtaining and maintaining sliding fee applications, verifying required patient information is present and complete, and apply the sliding fee discount in accordance with written policy. To ensure sliding fee discounts are properly calculated and documented, the Center should increase the frequency of random reviews of its sliding fee discount applications to help detect and correct errors or incomplete applications on a timely basis. In addition, the Center should provide additional training of staff involved in the application of sliding fee discounts. View of responsible officials and planned corrective action: The Center plans to: 1. Continue to provide frequent education and training for front-desk staff to assist in preparation and required completion of the sliding fee applications and proof of income forms. 2. Meet with front desk staff to identify and correct barriers to compliance with completion of sliding fee application and income verification and retention of those documents within the electronic record. 3. Develop workflow to identify when patients have exhausted their limited Medicaid dental benefits and would now qualify for sliding fee discount. Ensure sliding fee scale application and verification of income are completed prior to delivery of additional services. 4. Develop internal report to identify accounts with sliding fee scale identified with no end date recorded. For identified accounts, determine appropriate end date for sliding fee discount and enter it into the system. 5. Continue to do real time audits of front desk personnel to identify needs for additional training and to reinforce the process and appropriate documentation. 6. Institute a separate QA position for the purpose of review of patients with an identified sliding fee scale discount in place.