Audit 18116

FY End
2022-12-31
Total Expended
$2.19M
Findings
4
Programs
2
Year: 2022 Accepted: 2023-09-27

Organization Exclusion Status:

Checking exclusion status...

Findings

ID Ref Severity Repeat Requirement
22726 2022-001 Significant Deficiency - N
22727 2022-001 Significant Deficiency - N
599168 2022-001 Significant Deficiency - N
599169 2022-001 Significant Deficiency - N

Contacts

Name Title Type
EN5DQN9HKRB6 Gail Nelson Auditee
8003685182 Mary Jalbert Auditor
No contacts on file

Notes to SEFA

Title: Basis of Presentation Accounting Policies: Expenditures reported in the schedule of expenditures of federal awards (Schedule) are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles contained in Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), wherein certain types of expenditures are not allowable or are limited as to reimbursement. De Minimis Rate Used: Y Rate Explanation: Nehalem Bay Health Center and Pharmacy (the Organization) has elected to use the 10% de minimis indirect cost rate allowed under the Uniform Guidance. The Schedule includes the federal grant activity of the Organization. The information in this Schedule is presented in accordance with the requirements of the Uniform Guidance. Because the Schedule presents only a selected portion of the operations of the Organization, it is not intended to and does not present the financial position, changes in net assets, or cash flows of the Organization.

Finding Details

Finding Number: 2022-001 Finding Type(s): Significant deficiency in internal control over compliance; Non compliance related to sliding fee discounts special tests and provisions compliance requirement Information on the Federal Program: Program Name: Health Center Program Cluster (AL 93.224 and 93.527) Grant Award: 5 H80CS10593-14 from May 1, 2021 - April 30, 2022 and 5 H80CS10593-15 from May 1, 2022 - April 30, 2023 Agency: U.S. Department of Health and Human Services, Health Resources and Services Administration (HRSA) Criteria: In accordance with Section 330(k)(3)(G) of the Public Health Service Act (42 U.S. Code ? 254b), as an FQHC, the Organization must have a sliding fee discount program in which the Organization?s fee schedule is discounted based on a patient?s ability to pay. Condition: The Organization has not applied sliding fee discounts to patient charges consistent with its sliding fee discount program. Through testing a statistically valid sample of transactions for the appropriate application of the Organization's sliding fee discount program to 25 individual patient balances, we noted two patients did not have a valid application in effect for the date of service tested, resulting in the ineligible patients receiving discounts of approximately $275 and $168, respectively. Cause: Due to HRSA reporting requirements on the annual Universal Data System (UDS) report for specific patient demographic information, including patient income and family size, the same reporting tool within the the Organization's electronic health records (EHR) is used to capture data for both UDS reporting and sliding fee discount program eligibility. Patients applying for the sliding fee discount program would have the box "self declared" checked, for self declared income and family size, which would then be verified through the formal sliding fee discount application process. Patient accounts with this box checked will be automatically adjusted for sliding fee discounts. Patients not applying for the sliding fee discount program will have the box "self declared - pending approval" checked, resulting in data accumulation only. For the two patients in our sample, the incorrect box was checked resulting in the sliding fee discount being applied to the patient balances without a valid sliding fee application. The Organization has implemented internal monitoring procedures which include the review of sliding fee applications, however the procedures are not currently designed to sample discounts provided to patients to help ensure patients receiving a sliding fee discount are eligible and have a valid sliding fee application in accordance with the Organization's sliding fee discount policy. Effect: The Organization may not be applying sliding fee discounts to patient charges consistent with its sliding fee discount program, resulting in patients not eligible to receive a discount being provided a discount. Questioned Costs: None Repeat Finding: No Recommendation: We recommend management provide training to individuals involved in the patient intake and billing processes specific to the patient income and family size entry process and to modify internal monitoring procedures to include an emphasis in the sampling discounts applied to patient balances. Views of a Responsible Official and Corrective Action Plan: Management agrees with the finding and has implemented additional training and will update monitoring procedures to increase compliance with program requirements.
Finding Number: 2022-001 Finding Type(s): Significant deficiency in internal control over compliance; Non compliance related to sliding fee discounts special tests and provisions compliance requirement Information on the Federal Program: Program Name: Health Center Program Cluster (AL 93.224 and 93.527) Grant Award: 5 H80CS10593-14 from May 1, 2021 - April 30, 2022 and 5 H80CS10593-15 from May 1, 2022 - April 30, 2023 Agency: U.S. Department of Health and Human Services, Health Resources and Services Administration (HRSA) Criteria: In accordance with Section 330(k)(3)(G) of the Public Health Service Act (42 U.S. Code ? 254b), as an FQHC, the Organization must have a sliding fee discount program in which the Organization?s fee schedule is discounted based on a patient?s ability to pay. Condition: The Organization has not applied sliding fee discounts to patient charges consistent with its sliding fee discount program. Through testing a statistically valid sample of transactions for the appropriate application of the Organization's sliding fee discount program to 25 individual patient balances, we noted two patients did not have a valid application in effect for the date of service tested, resulting in the ineligible patients receiving discounts of approximately $275 and $168, respectively. Cause: Due to HRSA reporting requirements on the annual Universal Data System (UDS) report for specific patient demographic information, including patient income and family size, the same reporting tool within the the Organization's electronic health records (EHR) is used to capture data for both UDS reporting and sliding fee discount program eligibility. Patients applying for the sliding fee discount program would have the box "self declared" checked, for self declared income and family size, which would then be verified through the formal sliding fee discount application process. Patient accounts with this box checked will be automatically adjusted for sliding fee discounts. Patients not applying for the sliding fee discount program will have the box "self declared - pending approval" checked, resulting in data accumulation only. For the two patients in our sample, the incorrect box was checked resulting in the sliding fee discount being applied to the patient balances without a valid sliding fee application. The Organization has implemented internal monitoring procedures which include the review of sliding fee applications, however the procedures are not currently designed to sample discounts provided to patients to help ensure patients receiving a sliding fee discount are eligible and have a valid sliding fee application in accordance with the Organization's sliding fee discount policy. Effect: The Organization may not be applying sliding fee discounts to patient charges consistent with its sliding fee discount program, resulting in patients not eligible to receive a discount being provided a discount. Questioned Costs: None Repeat Finding: No Recommendation: We recommend management provide training to individuals involved in the patient intake and billing processes specific to the patient income and family size entry process and to modify internal monitoring procedures to include an emphasis in the sampling discounts applied to patient balances. Views of a Responsible Official and Corrective Action Plan: Management agrees with the finding and has implemented additional training and will update monitoring procedures to increase compliance with program requirements.
Finding Number: 2022-001 Finding Type(s): Significant deficiency in internal control over compliance; Non compliance related to sliding fee discounts special tests and provisions compliance requirement Information on the Federal Program: Program Name: Health Center Program Cluster (AL 93.224 and 93.527) Grant Award: 5 H80CS10593-14 from May 1, 2021 - April 30, 2022 and 5 H80CS10593-15 from May 1, 2022 - April 30, 2023 Agency: U.S. Department of Health and Human Services, Health Resources and Services Administration (HRSA) Criteria: In accordance with Section 330(k)(3)(G) of the Public Health Service Act (42 U.S. Code ? 254b), as an FQHC, the Organization must have a sliding fee discount program in which the Organization?s fee schedule is discounted based on a patient?s ability to pay. Condition: The Organization has not applied sliding fee discounts to patient charges consistent with its sliding fee discount program. Through testing a statistically valid sample of transactions for the appropriate application of the Organization's sliding fee discount program to 25 individual patient balances, we noted two patients did not have a valid application in effect for the date of service tested, resulting in the ineligible patients receiving discounts of approximately $275 and $168, respectively. Cause: Due to HRSA reporting requirements on the annual Universal Data System (UDS) report for specific patient demographic information, including patient income and family size, the same reporting tool within the the Organization's electronic health records (EHR) is used to capture data for both UDS reporting and sliding fee discount program eligibility. Patients applying for the sliding fee discount program would have the box "self declared" checked, for self declared income and family size, which would then be verified through the formal sliding fee discount application process. Patient accounts with this box checked will be automatically adjusted for sliding fee discounts. Patients not applying for the sliding fee discount program will have the box "self declared - pending approval" checked, resulting in data accumulation only. For the two patients in our sample, the incorrect box was checked resulting in the sliding fee discount being applied to the patient balances without a valid sliding fee application. The Organization has implemented internal monitoring procedures which include the review of sliding fee applications, however the procedures are not currently designed to sample discounts provided to patients to help ensure patients receiving a sliding fee discount are eligible and have a valid sliding fee application in accordance with the Organization's sliding fee discount policy. Effect: The Organization may not be applying sliding fee discounts to patient charges consistent with its sliding fee discount program, resulting in patients not eligible to receive a discount being provided a discount. Questioned Costs: None Repeat Finding: No Recommendation: We recommend management provide training to individuals involved in the patient intake and billing processes specific to the patient income and family size entry process and to modify internal monitoring procedures to include an emphasis in the sampling discounts applied to patient balances. Views of a Responsible Official and Corrective Action Plan: Management agrees with the finding and has implemented additional training and will update monitoring procedures to increase compliance with program requirements.
Finding Number: 2022-001 Finding Type(s): Significant deficiency in internal control over compliance; Non compliance related to sliding fee discounts special tests and provisions compliance requirement Information on the Federal Program: Program Name: Health Center Program Cluster (AL 93.224 and 93.527) Grant Award: 5 H80CS10593-14 from May 1, 2021 - April 30, 2022 and 5 H80CS10593-15 from May 1, 2022 - April 30, 2023 Agency: U.S. Department of Health and Human Services, Health Resources and Services Administration (HRSA) Criteria: In accordance with Section 330(k)(3)(G) of the Public Health Service Act (42 U.S. Code ? 254b), as an FQHC, the Organization must have a sliding fee discount program in which the Organization?s fee schedule is discounted based on a patient?s ability to pay. Condition: The Organization has not applied sliding fee discounts to patient charges consistent with its sliding fee discount program. Through testing a statistically valid sample of transactions for the appropriate application of the Organization's sliding fee discount program to 25 individual patient balances, we noted two patients did not have a valid application in effect for the date of service tested, resulting in the ineligible patients receiving discounts of approximately $275 and $168, respectively. Cause: Due to HRSA reporting requirements on the annual Universal Data System (UDS) report for specific patient demographic information, including patient income and family size, the same reporting tool within the the Organization's electronic health records (EHR) is used to capture data for both UDS reporting and sliding fee discount program eligibility. Patients applying for the sliding fee discount program would have the box "self declared" checked, for self declared income and family size, which would then be verified through the formal sliding fee discount application process. Patient accounts with this box checked will be automatically adjusted for sliding fee discounts. Patients not applying for the sliding fee discount program will have the box "self declared - pending approval" checked, resulting in data accumulation only. For the two patients in our sample, the incorrect box was checked resulting in the sliding fee discount being applied to the patient balances without a valid sliding fee application. The Organization has implemented internal monitoring procedures which include the review of sliding fee applications, however the procedures are not currently designed to sample discounts provided to patients to help ensure patients receiving a sliding fee discount are eligible and have a valid sliding fee application in accordance with the Organization's sliding fee discount policy. Effect: The Organization may not be applying sliding fee discounts to patient charges consistent with its sliding fee discount program, resulting in patients not eligible to receive a discount being provided a discount. Questioned Costs: None Repeat Finding: No Recommendation: We recommend management provide training to individuals involved in the patient intake and billing processes specific to the patient income and family size entry process and to modify internal monitoring procedures to include an emphasis in the sampling discounts applied to patient balances. Views of a Responsible Official and Corrective Action Plan: Management agrees with the finding and has implemented additional training and will update monitoring procedures to increase compliance with program requirements.