In this paper, we critique the performance of the node control volume finite element (NCVFE) method for modeling multi-phase fluid flow in heterogeneous media. The NCVFE method solves for the pressure at the vertices of elements and a control volume mesh is constructed around them. Material properties are defined on elements, while transport is simulated on the control volumes. These two meshes are not aligned producing inaccurate results and artificial fluid smearing when modeling multi-phase fluid flow in heterogeneous media. We perform numerical tests to quantify and visualize the extent of this artificial fluid smearing in domains with different material properties. The domains are composed of tetrahedron finite elements. Large artificial fluid smearing is observed in coarse meshes; however, it decreases with the increase in mesh resolution. These findings prompt the use of high-resolution meshes for the method and the need for development of novel numerical methods to address this unphysical flow.