Finding Text
Finding Number: 2023-001
Finding Type: Compliance - Special Tests and Provisions
Information on the Federal Program: Program Name: Health Center Program Cluster (AL numbers 93.224 and 93.527)
Grant Award: 2 H80CS00295-21 from March 1, 2022 through February 28, 2023 and 5 H80CS00295-22 from March 1, 2023 through February 29, 2024
Agency: U.S. Department of Health and Human Services, Health Resources and Services Administration
Pass-Through Entity: N/A
Criteria: In accordance with Section 330(k)(3)(G) of the PHS Act (42 U.S. Code § 254b), as an FQHC, the Organization must have a sliding fee discount program in which the Organization’s fee schedule is discounted based on a patient’s ability to pay.
Condition Found and Context: The Organization has not applied sliding fee discounts to patient charges consistent with its sliding fee discount program. Through testing a statistically valid sample of transactions for the appropriate application of the Organization's sliding fee discount program to 53 individual patient balances, we noted the sliding fee discount applied was not consistent with the Organization's sliding fee discount policy for two patients. Based on income and family size, both patients qualified for a Level 2 discount category with a patient responsibility of $20 but were awarded and received a Level 1 discount with a patient responsibility of $15.
Cause and Effect: Approval of the sliding fee discount applications involves manual processes and errors can occur. To help mitigate errors, the Organization has implemented monthly monitoring procedures which include the sampling of discounts provided to patient balances to ensure the appropriate discount level was awarded to the patient and the discount was appropriately applied to the patient's account consistent with the Organization's sliding fee discount program. The volume of discounts provided to patients annually does not allow for 100% review of all patient discounts and the inherent nature of sampling and as a result not all errors will be identified and corrected. It is possible the Organization may not apply sliding fee discounts to patient charges consistent with its sliding fee discount program.
Questioned Costs: None
Repeat Finding: No
Recommendation: We recommend management management review the current process for approval of applications and update the process as deemed appropriate. We also recommend management provide additional training to the individuals involved in the approval process. We further recommend management consider increasing the number of transactions reviewed as part of the Organization's internal monitoring procedures.
Views of a Responsible Official and Corrective Action Plan: Management agrees with the finding and will review the approval process and internal monitoring procedures for opportunities for improvement to increase compliance with the program requirements.