Marillac Community Health CentersNon-Profit

Criteria: Per HRSA Compliance Manual, Chapter 9: Sliding Fee Discount Program, Federally Qualified Health Centers (FQHCs) and similar entities are required to maintain and apply a Board-approved sliding fee scale based on income and family size. The scale must be applied uniformly to all eligible patients to ensure compliance with 42 U.S.C. § 254b and HRSA program requirements. Condition: During our testing of the sliding fee discounts under the Special Tests and Provisions compliance requirement, the audit team noted that the entity did not consistently apply its Board-approved sliding fee scale for medical and dental services. Specifically, in a nonstatistical sample of forty patient encounters tested, four instances were identified where the sliding fee discount applied was inconsistent with the entity’s approved sliding fee scale or was not supported by the documented patient income and family size information. The sampling methodology used is not, and is not intended to be, statistically valid. Cause: The condition appears to have resulted from inconsistent documentation obtained during the patient intake process and insufficient review controls to verify the accuracy of sliding fee discount determinations prior to application. Effect: Sliding fee discounts were not properly applied to patient accounts in accordance with the Board-approved sliding fee scale. Questioned Costs: None noted. Recommendation: The entity should strengthen internal controls over the sliding fee discount program to ensure discounts are applied accurately and consistently. Recommended actions include enhancing patient intake documentation requirements, implementing additional supervisory review of sliding fee determinations, providing refresher training to staff responsible for determining eligibility and intake processes, and performing more frequent monitoring to verify compliance with HRSA program requirements. View of Responsible Official: The organization has implemented additional levels of review and pre-screening of slide patient data to ensure accuracy and that the data is complete. Routine reviews done by front deck supervisors will be further documented in order to provide additional training to staff as needed. Results of monthly audits performed by service line leaders will be reported to senior leadership. An internal audit will be done by the compliance team and presented to leadership on a quarterly basis. All appropriate admitting staff will go through training to reinforce our slide process and review procedures for all FQHC services.