THE COLORADO COALITION FOR THE HOMELESS

Agency: Colorado Coalition for the Homeless Audit Period: 2025 Audit Finding Number: 2025-001 Audit Finding Title Sliding Fee Health Center Cluster Department of Health and Human Services Assistance Listing Number 93.224 Behavioral Health Services, 93.527 Bridge Access Program Award Numbers: 4 H8NCS53841-01-02 and 5 H80CS00040-24-00 Award Years: January 1, 2023-December 31, 2025 Criteria or Specific Requirement: Special Tests and Provision: Sliding Fee Discounts (42 USC 254(k)(3)(g); 42 CFR sections 51c.303(g); and 42 CFR sections 56.303 (f)) Condition: The Organization has a policy that includes homelessness when applying the sliding fee discount in addition to income and household size. The Health Center Compliance Manual only identifies income and household size as determining factors for the sliding fee program. Documentation to support income or household size were not maintained adequately for some patients who received sliding fee discount adjustments. Cause: The Organization's sliding fee discount policy includes homelessness, which is not specifically listed as an applicable determining factor for the sliding fee discount. The Health Center Compliance Manual specifically identifies income and household size as determining factors for the sliding fee program. Additionally, the Organization's controls did not clearly document eligibility for all patients with the sliding fee discount policy. Effect or potential effect: Other adjustments were not distinct from sliding fee adjustments applied to patient charges and, therefore, all patients received a full discount for services. Questioned Costs: None Context: A sample of 25 patients out of a population of 13,454 patients were tested.  Four of the patients sampled lacked appropriate documentation of income and/or household size. Seven of the patients sampled between 100% and 200% of the FPL were adjusted to no patient responsibility under the sliding fee discount program based on their homelessness status as identified in the Organization’s policy. The sampling methodology used is not and is not intended to be statistically valid. Identification as a repeat finding: Not a repeat finding. Recommendation: The Organization should revise its sliding fee discount policy to focus only on income and household size and further eliminate homelessness as a factor. Furthermore, the Organization should implement a process to review sliding fee discount eligibility to ensure compliance with its revised policy. Other adjustments should also be captured separately from sliding fee adjustments within the Organization's billing system. Views of responsible officials and planned corrective actions: The Organization agrees with the finding. Specific steps to be taken to correct the situation (including a timetable for performance of the CAP) or reason why corrective action is not necessary (including disagreement with the finding) NextGen, the electronic health record and practice management system CCH utilizes for revenue cycle operations has been reconfigured to separate the sliding fee adjustments from other adjustments. This was identified and corrected before the audit was completed on April 21, 2026. CCH will revise and update the Sliding Fee Discount Program policy to clarify that the only two factors for application of the sliding fee discount are family size and income. The Sliding Fee Discount Policy will no longer include ‘homelessness’ as a factor for this particular discount. CCH will review the sliding fee discount process regularly to ensure compliance with the revised policy. Additionally, appropriate documentation of self-attestation of income and family size will be collected as required. CCH will also revise and update existing policies related to Billing and Collections and for Waiving or Reducing Fees Beyond the Sliding Fee Scale to define the other discounts CCH provides to clients including those who do not provide complete data for sliding fee discount eligibility determination Finally, appropriate staff will receive updated training on the updated policies. Anticipated completion date The billing system change occurred on April 21, 2026. The policy revisions will be completed and approved by the Board by October 31, 2026 Training on the updated policies will be implemented upon final approval by the Board and be completed by November 30, 2026. Name(s) and title(s) of contact person(s) responsible for corrective action Billing system changes: Rob Plimpton, Controller /Kathy Hatfield, Interim Revenue Cycle Director Policies and Training: Andrew RobGrimm, Chief Integrated Health Operations Officer