Neighborhood Health Care, Inc.

Condition: NFP improperly applied sliding fee discounts to numerous unverified patients and services. NFP applied sliding fee scale discounts not in accordance with established policies and did not have appropriate controls in place to prevent and detect the application of improper sliding scale fee discounts. Criteria: NFP is required by HRSA to comply with the requirements of the sliding fee discount schedule (SFDS) and apply sliding fee scale discounts in accordance with established NFP policies. NFP is required to design and implement controls to ensure sliding scale fee discounts are only applied to qualifying individuals and families, and sliding fee scale discounts are applied only to services that meet NFP’s established policies. Cause: An error in NFP’s automated write-off rules in its patient software caused certain patients and services to be written off as a sliding scale discount. NFP had not designed and implemented internal controls to prevent and detect improper application of sliding fee scale discounts. Effect: Non-compliance with the requirements of the sliding scale discount program. Recommendation: We recommend NFP ensures sliding scale fee discounts are only applied to income-verified individuals and no sliding fee scale discount applied to individuals and families above 200 percent of the Federal Poverty Guidelines (FPG). We recommend NFP review its processes, procedures and controls to ensure they are appropriately designed, implemented and operating effectively to prevent, detect and correct improper sliding fee scale discounts. Views of Responsible Officials and Planned Corrective Actions: NFP concurs with this finding and notes the $52,982 of questioned costs were written off to the wrong adjustment code due to the automated write-off with the patient software. NFP identified the issue in December of 2022 and the Vice President of Compliance and Chief Financial Officer performed a root cause analysis as to the starting point. Management corrected the write-off with the patient software that was causing the automated adjustments when initially identified. Management will continue to audit and review the automated write-off with the patient software on a quarterly/monthly basis (as determined) going forward as well as implementing procedures to ensure the sliding scale eligible visits are properly documented and adjusted in the billing system.