Clinica Campesina Family Health ServicesNon-Profit

2024 – 001 Special Tests: Application of Sliding Fee Discount Federal Agency: U.S. Department of Health and Human Services Federal Program: Consolidated Health Centers Grant AL Number: 93.224 & 93.527 Award Period: 2/1/23 - 1/31/24 Type of Finding: Significant deficiency in Internal Control over Compliance and Compliance Criteria or Specific Requirement Per Title 42 Chapter 1 Subchapter D Section 51c303(f), “Health centers must have a schedule of fees or payments for the provision of their health services consistent with locally prevailing rates or charges designed to cover their reasonable costs of operation. They are also required to have a corresponding schedule of discounts applied and adjusted on the basis of the patient’s ability to pay.” Condition and Context During our testing of forty sliding fee discounts for health center patients qualifying for reduced charge visits, we identified one visit where a sliding fee application could not be found to support the slide provided. Effect Potential that a patient would not receive the appropriate sliding fee discount. Questioned Costs None identified. Cause Clerical error in which the sliding fee application was not saved in the patients file. Recommendation We recommend the Organization to review internal controls in regards to retaining the completed sliding fee applications in the patients record to support the sliding fee discount provided to the patient. Views of Responsible Officials The Organization is aware of the importance of properly applying the sliding fee scale to all eligible patients. We feel that we have strong policies and procedures to ensure this is performed accurately. However, the process is dependent on many individuals and is susceptible to human error. We will implement the following process to mitigate this risk. We will increase our internal audit procedures to audit sliding fee applications on a more frequent basis for any Enrollment Specialist who fails to maintain a 5% error rate. We will increase the number of Sliding Fee Discount applications to 5 every month. We will also conduct a retraining with the team to ensure all documents are uploaded into the document management system correctly for each patient.

Finding 2019-001: Application of Sliding Fee Discount Federal Agency: U.S. Department of Health and Human Services Federal Program: Consolidated Health Centers Grant CFDA Number: 93.224 and 93.527 Award Period: February 1, 2018 to January 31, 2019 Type of Finding: Significant Deficiency in Internal Control over Compliance and Compliance Criteria Per Title 42 Chapter 1 Subchapter D Section 51c303(f), ?Health centers must have a schedule of fees or payments for the provision of their health services consistent with locally prevailing rates or charges designed to cover their reasonable costs of operation. They are also required to have a corresponding schedule of discounts applied and adjusted on the basis of the patient?s ability to pay.? Condition Found and Context During our testing of 40 sliding fee discounts for health center patients qualifying for reduced charge visits, we identified one visit that received the incorrect sliding fee discount. Effect Potential that a patient would not receive the appropriate sliding fee discount. Cause Clerical error in updating and applying the sliding fee category in the billing system for these patients caused this oversight. Recommendation We recommend the Organization take measures to ensure that appropriate sliding fee rates/categories are used for each sliding fee encounter. Views of Responsible Officials and Planned Corrective Actions The Organization is aware of the importance of properly applying the sliding fee scale to all eligible patients. We feel that we have a strong policy and procedure to ensure this is done accurately. However, the process is dependent on many individuals and is susceptible to human error. We have implemented two new processes to mitigate this risk. First, we are working with our electronic health records company (NextGen) to improve the electronic process. We will enter the family size and income into NextGen, which will automatically assign the correct sliding fee scale, which will automatically be applied each time the patient utilizes the clinic. Secondly, we are increasing our internal audit procedures to audit sliding fee applications on a monthly basis, previously we were performing quarterly audits. These more frequent audits will ensure that information from the applications is accurately entered into NextGen.