Finding Text
2022-001 Federal Program CFDA # 93.224 and 93.527 Health Center ClusterSignificant deficiency in internal control over federal award program - Special Tests and Provisions: Sliding Fee DiscountsCriteria ?Pursuant to 2 CFR 200 and the Uniform Guidance, and as noted in the compliance supplement. 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. The Center may establish a sliding fee discount schedule, approved by the governing board, provided certain criteria in the compliance supplement are met. The Center has established an appropriate policy and sliding fee scale.Condition ?In testing discounts given to patients under the Center?s sliding fee policy, we noted instances where personnel were not following Center guidelines. As required by the Center?s sliding fee discount policy, patients are required to annually renew their applications, to sign and date the applications. Additionally, patients are required to provide income verification annually or within 30 days of service for new patients. We noted instances where existing patients did not have a signed application on file and/or no income support documentation was maintained.Context -A non-statistical sample of 25 sliding fee encounters was selected. In our sample we noted two sliding fee encounters did not have supporting documentation in the file.Effect -Sliding fee encounters that occur without the appropriate family size and annual income information could result in patients not being charged the appropriate fee and/or received an incorrect sliding fee discount.Cause -Employees responsible for implementation and documentation of sliding fee discounts were not monitored to adequately verify processes were being performed as prescribed. Additionally, specific procedures for telehealth visits were not in place and guidance was not readily available to management.Recommendation -Auditors recommend additional training for staff on sliding fee policies and procedures and management monitor and verify processes are being performed as prescribed on a reoccurring basis.Views of Responsible Officials -We concur with the audit finding. While the Center has a policy that meets the compliance requirements, management is responsible for the implementation and monitoring of those processes and procedures. Additional staff training on slide fee discounts is in place and monthly review and testing of compliance with Center sliding fee discount policy will be done.