Finding Text
2023-001 Retaining Sliding Scale Determination Documentation
Special Tests and Provisions
ALN 93.224 Health Center Program (Community Health Centers, Migrant Health Centers,
Health Care for the Homeless, and Public Housing Primary Care)
US Department of Health and Human Services
Contract Numbers H80CS30749-06 and H80CS30749-07
Contract Periods April 1, 2022 – March 31, 2023 and April 1, 2023 – March 31, 2024
Conditions and Criteria: The requirement under 45 CFR 75.361 provides requirements for the retention of
records for grantees. In addition, 2 CFR 200.303 provides requirements to establish and maintain
effective internal controls over Federal awards. Specifically, it states that financial records, supporting
documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must
be retained for a period of three years from the date of submission of the final expenditure report or, for
Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or
annual financial report, respectively, as reported to the Health and Human Services awarding agency of
pass-through entity in the case of a subrecipient. In the 2023 audit, for 5 out of 40 samples selected for
testing, it was noted that OCHS did not retain the proper documents that the patients had submitted that
included their income and family size or the documents completed by OCHS showing the sliding fee
discount determination for these patients.
Effect: The effect is that records that are required to be retained were not retained and evidence of how
the sliding fee discount was determined could not be examined.
Questioned Costs: Any likely questioned costs could not be determined since compliance testing was
unable to be performed due to the lack of documentation. It should be noted that there were no
exceptions for 35 samples that were able to be tested, and for 5 samples with insignificant
documentation, 3 had partial documentation of income (i.e., pay stubs) and 2 had no documentation of
income as it was not maintained. However, the sliding scale calculation was completed for all 40 samples.
Cause: Determining the sliding fee discount level for each patient is reassessed on an annual basis.
During the year, there was employee turnover in the compliance department. Although OCHS has a
records retention policy, there was a lack of monitoring in place to ensure that the requirement under 45
CFR 75.361 was adhered to.
Auditor Recommendation: A procedure should be put in place to monitor whether the record retention
policy is followed.
Planned Corrective Action: See the following Corrective Action Plan section for management’s planned
corrective action.