Valley-Wide Health Systems, Inc.

Criteria or Specific Requirement – In accordance with the Health Resources & Services Administration Health Center Program Compliance Manual, Chapter 9: Sliding Fee Discount Program, health centers must prepare and apply a sliding fee discount schedule so that amounts owed for health care services by eligible patients are adjusted based on the patients’ ability to pay. In accordance with 42 CFR 56.303, health centers must have a schedule of fees or payments for the provision of their health services consistent with locally prevailing rates or charges and designed to cover their reasonable costs of operation. They are also required to have a corresponding schedule of discounts applied and adjusted based on the patient’s ability to pay. The patient’s ability to pay is determined based on the official poverty guidelines, as revised annually by U.S. Department of Health and Human Services (HHS). The schedule of discounts must provide for a full discount to individuals and families with annual incomes at or below those set forth in the most recent poverty income guidelines (except that nominal fees for service may be collected from such individuals and families) and for no discount to individuals and families with annual incomes greater than twice those set forth in such guidelines. Condition – Patient co‐payments and the Sliding Fee Discount Program adjustments were incorrect for three patients selected. Context – A sample of 40 encounters with Sliding Fee Discount Program adjustments totaling $9,030 was selected for testing from a population of 6,059 encounters with Sliding Fee Discount Program adjustments totaling $1,377,546. Our testing found three encounters had an incorrect Sliding Fee Discount Program adjustment applied, resulting in $30 of questioned costs. Cause –Information for three of the patients tested was improperly input into the billing system. These errors resulted in an incorrect copayment being charged and the related Sliding Fee Discount Program adjustment being made incorrectly. Effect or Potential Effect – Certain adjustments to the Sliding Fee Discount Program were not being recorded properly. Questioned Costs – Questioned costs are computed as the variance between the Sliding Fee Discount Adjustments applied and the correct Sliding Fee Discount Adjustments. Recommendation – We recommend that procedures be put in place to insure patient data is correctly entered into the billing software. View of Responsible Officials and Planned Corrective Actions – Management agrees with the finding and will ensure documentation and processed regarding the Sliding Fee Discount Program and adhered to.