Finding Text
2002-003 - Special Test and Provisions ? Sliding Fee Discounts Significant Deficiency over Internal Controls over Compliance Federal Assistance Listing Number: 93.224 Name of Federal Program or Cluster: Health Centers Program Cluster Federal Agency/Pass-Through Entity: U.S. Department of Health and Human Services Federal Award Number: H80CS12872 & H8F41209 Award Year: 2021-2022 Criteria: In accordance with OMB No. 0915-0193, the Uniform Data System (UDS) report is required to be submitted for the Health Centers Cluster program annually on a calendar year basis. In accordance with 42 CFR 56.303, health centers must have a schedule of fees or payments for the provision of their health services consistent with locally prevailing rates or charges and designed to cover their reasonable costs of operation. They are also required to have a corresponding schedule of discounts applied and adjusted based on the patient?s ability to pay. The patient?s ability to pay is determined based on the official poverty guidelines, as revised annually by U.S. Department of Health and Human Services (HHS). The schedule of discounts must provide for a full discount to individuals and families with annual incomes at or below those set forth in the most recent poverty income guidelines (except that nominal fees for service may be collected from such individuals and families) and for no discount to individuals and families with annual incomes greater than twice those set forth in such Guidelines. Condition: The Organization determines the amount of fees to be charged to the patients based on their annual gross income and household size in conjunction with the sliding fee schedule. During our testing of sliding fee discount, we noted the following: - One (1) out of 65 patients selected was given a sliding fee discount when the patient did not qualify for any discount under the program, resulting in overstatement of the sliding fee discount by $10. - Five (5) out of 65 selections were given a discount that was not consistent with the scale for which they were eligible based on their proof of income, resulting understatement of the sliding fee discount by $79.91. Questioned Costs: $69.91 of the $704.12 patient charges sampled. Context: The audit findings represent a systematic problem, see condition above. Effect: Patients were improperly categorized on the Organization?s sliding fee scale and were given an improper sliding fee discount. Cause: The inaccuracies in the application of the sliding fee program discounts were due to human error and inadequate oversight and review Recommendation: We recommend that the Organization?s procedures be strengthened to ensure 1) income is properly verified and adequately documented and 2) the sliding fee discount is properly determined and applied. The Organization should strengthen processes surrounding monitoring of the program to ensure the Organization?s policies are consistently and properly applied. Repeat finding: This is a similar repeat finding to last year audit #2021-002. Views of Responsible Officials and Planned Corrective Actions: The Organization will strengthen procedures to ensure discounts for sliding fee is applied consistently and accurately. Immediately, the Organization will conduct monthly application audits. An audit of 25 sliding fee application forms completed in the month prior will be examined for accuracy, along with their supporting data. All information from these applications will be cross-verified in NextGen. The results from the sliding fee monthly audits will be monitored and reported quarterly at the Quality Assurance and Quality Improvement meetings. Furthermore, the Organization will continue the practice of conducting skills assessments at the start of the year and once more in July. These assessments are crucial as they help pinpoint staff members who might benefit from refresher training. Moreover, a meeting has been scheduled to finalize the days and times for virtual sliding fee application training. This training, aimed at all staff who handle a sliding fee form, will be spread out over four weeks, with one session per week lasting an hour. Additionally, the Organization will introduce a sliding fee training video to the new employee orientation. After completing their NextGen training, staff will receive this training video via email. Furthermore, this video will also be sent to all health center leadership to be utilized at the health center level.