Near North Health Service CorporationNon-Profit

2022-001 Special Tests and Provisions ? Sliding Fee Discounts Major Program ? Health Center Program Cluster Assistance Listing Number ? 93.224 Federal Agency ? U.S. Department of Health and Human Services Finding Type ? Significant Deficiency Criteria or Specific Requirement ? Special Tests and Provisions ? In accordance with Health Resources & Services Administration Health Center Program Manual, Chapter 9: Sliding Fee Discount Program and 42 CFR sections 51c.303(e), (f) and (g), health centers must prepare and apply a sliding fee discount schedule so that the amounts owed to health center services by eligible patients are adjusted based on the patient?s ability to pay. No sliding fee discount is applied to fees for health center services provided to individuals and families with annual incomes above 200 percent of the Federal Poverty Guidelines (FPG). Condition ? In a sample of tested encounters, patient information was inadequate to determine whether the proper sliding fee discount was applied. Questioned Costs ? None. Context ? Out of 40 encounters sampled, the following was identified: (1) For 3 out of 40, the Organization failed to perform recurring verification of income, allowing some patients who have never formally applied or may have updated income that would have changed the sliding fee discount to have a reduced charge. (2) For 7 out of 40, the Organization obtained verbal verification of income and no formal verification or proof of income was obtained prior to the Organization providing services; and (3) For 3 out of 40, the patient was registered properly as a Medicaid patient but was subsequently improperly transferred to a sliding fee and no application or verification of income was obtained. The sampling was not a statistically valid sample. Effect ? As a result, 13 patients received the sliding fee discount without the proper documentation to support that they were eligible for the discount or received the appropriate level of discount based on income. Cause ? The inaccuracies in the application of the sliding fee program discounts appear to be due to inadequate oversight and review. Repeat Finding ? Yes; 2021-003, 2020-003 Recommendation ? The Organization should strengthen processes surrounding monitoring of the program to ensure that the Organization?s policies are consistently and properly applied. Management should periodically audit the sliding fee encounters for appropriate discount determination. Views of Responsible Officials and Planned Corrective Actions ? Management will ensure that adequate documentation is maintained to support the sliding fee discount and documentation used to calculate the discount is reviewed by a supervisor.

Assistance Listing Number, Federal Agency, and Program Name - U.S. Department of Health and Human Services, ALN 93.224, Consolidated Health Centers Federal Award Identification Number and Year H80CS00194, H8DCS36113, H8CS38120 Pass through Entity - N/A Finding Type - Significant deficiency Repeat Finding - Yes 2020-003 Criteria - In accordance with the Health Resources & Services Administration Health Center Program Compliance Manual, Chapter 9: Sliding Fee Discount Program and 42 CFR sections 51c.303(e), (f), and (g), health centers must prepare and apply a sliding fee discount schedule so that amounts owed for health center services by eligible patients are adjusted based on the patients? ability to pay. No sliding fee discount is applied to fees for health center services provided to individuals and families with annual incomes above 200 percent of the Federal Poverty Guidelines (FPG). Condition - In a sample of tested encounters, patient information was inadequate to determine whether the proper sliding fee discount was applied. Questioned Costs - None Identification of How Questioned Costs Were Computed N/A Context - Out of 25 encounters sampled, two encounters did not have documentation to support that the patient was eligible for the sliding fee discount applied nor documentation to support the level of discount provided. Cause and Effect - The inaccuracies in the application of the sliding fee program discounts were due to inadequate oversight and review. As a result, two patients received the sliding fee discount without proper documentation to support they were eligible for the discount or received the appropriate level of discount based on income. Recommendation - The Organization should strengthen processes surrounding monitoring of the program to ensure that the Organization's policies are consistently and properly applied. Management should periodically audit the sliding fee encounters for appropriate discount determination. Views of Responsible Officials and Corrective Action Plan - Management will ensure that adequate documentation is maintained to support the sliding fee discount and documentation used to calculate the discount is reviewed by a supervisor.

CFDA Number, Federal Agency, and Program Name - CFDA 93.224 Community Health Centers Grant and COVID-19 Coronavirus Supplemental Funding for Health Centers; CFDA 93.527 Health Center Controlled Networks Federal Award Identification Number and Year - H80CS00194, H8CCS34454, and H2QCS30242 Pass through Entity - N/A Finding Type - Significant deficiency Repeat Finding - No Criteria - Health centers must prepare and apply a sliding fee discount schedule so that the amounts owed for health center services by eligible patients are discounted based on the patients' ability to pay (42 USC 254b(k)(3)(G)(i)). The patient's ability to pay is determined based on the official poverty income guideline, as revised annually by HHS (42 CR sections 51c. 107(b)(5), 56.108(b)(5), and 56.303(f)). Condition - Either adequate documentation was not maintained to support the sliding fee discount provided to the patient or the family size used for the calculation of the sliding fee discount did not agree to the application completed by the patient. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - In a sample of 3 out of 25 selected for testing, it was noted that either adequate documentation was not maintained to support the sliding fee discount provided to the patient or the family size used for the calculation of the sliding fee discount did not agree to the application completed by the patient. In all three instances, there were no inaccuracies in the calculation of the sliding fee discount. Cause and Effect - Management did not retain required documentation to support the sliding fee calculations and did not adequately review data input from applications. Recommendation - We recommend that management continue to ensure that all required documentation is maintained and reviewed in order to support the sliding fee discount calculations. Views of Responsible Officials and Corrective Action Plan - Adequate documentation is maintained to support the sliding fee discount. We will ensure that all documentation used to calculate the sliding fee discount is reviewed by the supervisor.

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