Audit 31346

Finding Number: 2022-001 Finding Type: Material Weakness - Special Tests and Provisions Information on the Federal Program: Program Name: COVID-19 Consolidated Health Center (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) (AL 93.224) Project Title: American Rescue Plan Act Funding for Look-Alikes Grant Award: 1 L2CCS42360-01 from July 1, 2021 through June 30, 2023 Agency: U.S. Department of Health and Human Services, Health Resources and Services Administration Pass-Through Entity: N/A Criteria: In accordance with Section 330(k)(3)(G) of the Public Health Service Act (42 U.S. Code ? 254b), as an FQHC Look-Alike, the Center must have a sliding fee discount program in which the Center?s fee schedule is discounted based on a patient?s ability to pay. Condition and Context: The Center 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 Center's sliding fee discount program to 25 individual patient balances, we noted the following: ? An approved sliding fee application was not able to be located for one patient ? The approved sliding fee application did not support either the family size or the income used to determine program eligibility for four patients ? Two Category B patients (patients with income 101-138% of the Federal Poverty Level (FPL)) had their balances adjusted in accordance with the sliding fee discount schedule but which resulted in a lower patient responsibility than that of a Category A patient (patients with income less than 100% of the FPL) ? The sliding fee discount applied to one patient balance had a trivial error in the discount Cause and Effect: The Center's sliding fee discount program policy does not have clear definitions of family size and income used to determine program eligibility. Additionally, the Center does not use a standardized form for the calculation of a patient's income to support the amount entered into the Center's electronic health records (EHR) system. The Center also has limited internal monitoring procedures established for ensuring compliance with the sliding fee discount program. The errors resulted in the following deviations from the Organization's sliding fee discount program: ? Two patients did not qualify for the sliding fee discount program but received discounts of $96.60 and $64.40 ? Two Category B patients were responsible to pay $2.20 and $2.85 less than a Category A patient would have been responsible to pay ? One patient was responsible to pay $0.10 less than required Questioned Costs: None Repeat Finding: No Recommendation: We recommend the following: ? Update the sliding fee discount program policy to more clearly define family size and income, including examples of source documents ? Create and use a form to document the calculation of the household income entered into the EHR ? Review the complexity of the discount schedule and consider whether it would be beneficial to change the schedule from percentage discounts to flat dollar amounts for Category B, C, D and E ? Develop routine internal monitoring procedures to perform periodic testing of sliding fee discounts to help ensure the discounts are provided consistent with the Center?s sliding fee discount program Views of a Responsible Official and Corrective Action Plan: Management agrees with the finding. Policies and procedures will be updated as appropriate and routine and timely documented reviews of sliding fee discounts will be completed to ensure compliance with the Center's sliding fee discount program.

Finding Number: 2022-001 Finding Type: Material Weakness - Special Tests and Provisions Information on the Federal Program: Program Name: COVID-19 Consolidated Health Center (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) (AL 93.224) Project Title: American Rescue Plan Act Funding for Look-Alikes Grant Award: 1 L2CCS42360-01 from July 1, 2021 through June 30, 2023 Agency: U.S. Department of Health and Human Services, Health Resources and Services Administration Pass-Through Entity: N/A Criteria: In accordance with Section 330(k)(3)(G) of the Public Health Service Act (42 U.S. Code ? 254b), as an FQHC Look-Alike, the Center must have a sliding fee discount program in which the Center?s fee schedule is discounted based on a patient?s ability to pay. Condition and Context: The Center 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 Center's sliding fee discount program to 25 individual patient balances, we noted the following: ? An approved sliding fee application was not able to be located for one patient ? The approved sliding fee application did not support either the family size or the income used to determine program eligibility for four patients ? Two Category B patients (patients with income 101-138% of the Federal Poverty Level (FPL)) had their balances adjusted in accordance with the sliding fee discount schedule but which resulted in a lower patient responsibility than that of a Category A patient (patients with income less than 100% of the FPL) ? The sliding fee discount applied to one patient balance had a trivial error in the discount Cause and Effect: The Center's sliding fee discount program policy does not have clear definitions of family size and income used to determine program eligibility. Additionally, the Center does not use a standardized form for the calculation of a patient's income to support the amount entered into the Center's electronic health records (EHR) system. The Center also has limited internal monitoring procedures established for ensuring compliance with the sliding fee discount program. The errors resulted in the following deviations from the Organization's sliding fee discount program: ? Two patients did not qualify for the sliding fee discount program but received discounts of $96.60 and $64.40 ? Two Category B patients were responsible to pay $2.20 and $2.85 less than a Category A patient would have been responsible to pay ? One patient was responsible to pay $0.10 less than required Questioned Costs: None Repeat Finding: No Recommendation: We recommend the following: ? Update the sliding fee discount program policy to more clearly define family size and income, including examples of source documents ? Create and use a form to document the calculation of the household income entered into the EHR ? Review the complexity of the discount schedule and consider whether it would be beneficial to change the schedule from percentage discounts to flat dollar amounts for Category B, C, D and E ? Develop routine internal monitoring procedures to perform periodic testing of sliding fee discounts to help ensure the discounts are provided consistent with the Center?s sliding fee discount program Views of a Responsible Official and Corrective Action Plan: Management agrees with the finding. Policies and procedures will be updated as appropriate and routine and timely documented reviews of sliding fee discounts will be completed to ensure compliance with the Center's sliding fee discount program.