Ryan Chelsea-Clinton Community Health Center, Inc.Non-Profit

Finding 2023-002 – Health Centers Cluster Federal Agency – U.S. Department of Health and Human Services Grant Period – Year ended December 31, 2023 Criteria - Health centers must prepare and apply a sliding fee discount schedule (SFDS) so that the amounts owed for health center services by eligible patients are adjusted (discounted) based on the patient’s ability to pay. The health center must demonstrate adjustments to charges are consistent with the health center’s SFDS. Condition - We attempted to recalculate the applied discount using the Center’s policy and the patient documentation provided, noting instances where the adjustments to charges were inconsistent with the Center’s SFDS. Cause - Lack of controls to ensure that staff are obtaining required documentation and entering the information correctly. Effect - Out of our sample of 20 selections, we identified five exceptions based on the SFDS. Three of the discounts entered lacked the required slide documentation, the slide form had expired and was not updated, or the document was updated, but the data in the system was not resulting in the slide that was provided not being supported or applied incorrectly. Two of the discounts were improperly adjusted during the billing or review process based on insurance or payments received, or incorrect charges being calculated and applied to the total slide for the remaining patient balance. Recommendation - Providing the sliding fee to patients is a requirement of specific grant funds received. As such, we recommend the Center review the current procedures in place and consider additional and more frequent training for all employees involved in the process. We encourage management to consider appointing an individual at the various locations to assist the front desk staff with the sliding fee process to ensure required documentation is captured and recorded accurately in the billing system. We also encourage the Center to consider assigning a dedicated individual to regularly review the sliding fee visits to ensure compliance. This should be someone who is knowledgeable of the sliding fee requirements and the Center’s billing processes and procedures.

Criteria: Per the Uniform Guidance, sliding fee discounts are applied to fees for health center services provided to all individuals and families with annual incomes at or below 200 percent of the Federal Poverty Guidelines (?FPG?). Fees for health center services are discounted based on gradations in family size and income for individuals and families with incomes above 100 percent and at or below 200 percent of the FPG. Condition: For 20 out of 60 self-pay patients selected, although the Center did apply a sliding fee discount, the amount of sliding fee discount applied was not appropriate based on the Center?s sliding fee discount schedule in effect. Cause: The sliding fee discount scale selected was incorrect based on patient?s income level. Effect: The Center did not comply with program requirements requiring use of the Center?s sliding fee discount schedule. Questioned Costs: None noted Context: This condition was only encountered within our testing of certain dental and vision self-pay visits. Self-pay dental and vison visits represented approximately 4% of the Center?s 2020 visits. Recommendation: We recommend that the Center provide additional training to personnel in the dental and vision departments to ensure sliding fee discounts provided to income eligible patients are in accordance with Center?s approved sliding fee schedule.