Audit 321590

Finding 2023-002 Application of Sliding Fee Discount Program Information: Federal Agency U.S. Department of Health and Human Services Federal Assistance Listing Number 93.224 and 93.527 Health Center Program Cluster Award Number H80CS40219 Criteria [X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness OMB 2 CFR 200, Subpart F Compliance Supplement, Part 4, Compliance Requirement N, Special Tests and Provisions states, “Health centers must prepare and apply a sliding fee discount schedule so that the amounts owed for health center services by eligible patients are adjusted (discounted) based on the patient’s ability to pay.” Condition In our testing of 40 sliding fee discounts for health center patients qualifying for reduced charge visits, we identified 1 instance where no application was maintained. We also identified 6 instances where the incorrect sliding fee was applied to the patient. Cause The Center did not have a review process in place to verify eligible patients completed the required application to receive a sliding fee discount and that each application contained the required information. Additionally, the Center did not verify the correct sliding fee discount was based on the Center’s sliding fee scale. Context The finding appears to be a systemic problem. Effect Missing applications could indicate that patients who received a sliding fee discount may not have been eligible. Additionally, the sliding fee discount could be applied incorrectly and not in accordance with the Center’s policy. Recommendation We recommend developing proper controls around obtaining and maintaining sliding fee applications, verifying required patient information is present and complete, and apply the sliding fee discount in accordance with written policy. To ensure sliding fee discounts are properly calculated and documented, the Center should increase the frequency of random reviews of its sliding fee discount applications to help detect and correct errors or incomplete applications on a timely basis. In addition, the Center should provide additional training of staff involved in the application of sliding fee discounts. View of responsible officials and planned corrective action. GVHC implemented the physical review and controls described in the 2022 audit response. Our efforts were largely successful as the missing application was the only failure of the physical audit process we put in place. However, a failure of our technology and billing software was revealed. Our plan it to: 1. Continue to provide frequent education and training for front-desk staff to assist in preparation and required completion of the sliding fee applications and proof of income. 2. Continue to identify patients who have exhausted their limited Medicaid benefits and will now qualify for sliding fee scale for dental work. 3. Continue to review reports identifying patients with no end date identified for their sliding fee scale. For identified accounts, determine correct date and enter in the system. 4. Continue 100% audit of all sliding fee scale applications for accuracy of calculation and presence of necessary paperwork. Provide direct feedback to staff when errors are identified. Integrate changes to billing software into the process when sliding fee scales are adjusted and posted. Run reports of sliding fee scale discounts and audit for correct calculation.

Finding 2023-002 Application of Sliding Fee Discount Program Information: Federal Agency U.S. Department of Health and Human Services Federal Assistance Listing Number 93.224 and 93.527 Health Center Program Cluster Award Number H80CS40219 Criteria [X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness OMB 2 CFR 200, Subpart F Compliance Supplement, Part 4, Compliance Requirement N, Special Tests and Provisions states, “Health centers must prepare and apply a sliding fee discount schedule so that the amounts owed for health center services by eligible patients are adjusted (discounted) based on the patient’s ability to pay.” Condition In our testing of 40 sliding fee discounts for health center patients qualifying for reduced charge visits, we identified 1 instance where no application was maintained. We also identified 6 instances where the incorrect sliding fee was applied to the patient. Cause The Center did not have a review process in place to verify eligible patients completed the required application to receive a sliding fee discount and that each application contained the required information. Additionally, the Center did not verify the correct sliding fee discount was based on the Center’s sliding fee scale. Context The finding appears to be a systemic problem. Effect Missing applications could indicate that patients who received a sliding fee discount may not have been eligible. Additionally, the sliding fee discount could be applied incorrectly and not in accordance with the Center’s policy. Recommendation We recommend developing proper controls around obtaining and maintaining sliding fee applications, verifying required patient information is present and complete, and apply the sliding fee discount in accordance with written policy. To ensure sliding fee discounts are properly calculated and documented, the Center should increase the frequency of random reviews of its sliding fee discount applications to help detect and correct errors or incomplete applications on a timely basis. In addition, the Center should provide additional training of staff involved in the application of sliding fee discounts. View of responsible officials and planned corrective action. GVHC implemented the physical review and controls described in the 2022 audit response. Our efforts were largely successful as the missing application was the only failure of the physical audit process we put in place. However, a failure of our technology and billing software was revealed. Our plan it to: 1. Continue to provide frequent education and training for front-desk staff to assist in preparation and required completion of the sliding fee applications and proof of income. 2. Continue to identify patients who have exhausted their limited Medicaid benefits and will now qualify for sliding fee scale for dental work. 3. Continue to review reports identifying patients with no end date identified for their sliding fee scale. For identified accounts, determine correct date and enter in the system. 4. Continue 100% audit of all sliding fee scale applications for accuracy of calculation and presence of necessary paperwork. Provide direct feedback to staff when errors are identified. Integrate changes to billing software into the process when sliding fee scales are adjusted and posted. Run reports of sliding fee scale discounts and audit for correct calculation.

Finding 2023-002 Application of Sliding Fee Discount Program Information: Federal Agency U.S. Department of Health and Human Services Federal Assistance Listing Number 93.224 and 93.527 Health Center Program Cluster Award Number H80CS40219 Criteria [X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness OMB 2 CFR 200, Subpart F Compliance Supplement, Part 4, Compliance Requirement N, Special Tests and Provisions states, “Health centers must prepare and apply a sliding fee discount schedule so that the amounts owed for health center services by eligible patients are adjusted (discounted) based on the patient’s ability to pay.” Condition In our testing of 40 sliding fee discounts for health center patients qualifying for reduced charge visits, we identified 1 instance where no application was maintained. We also identified 6 instances where the incorrect sliding fee was applied to the patient. Cause The Center did not have a review process in place to verify eligible patients completed the required application to receive a sliding fee discount and that each application contained the required information. Additionally, the Center did not verify the correct sliding fee discount was based on the Center’s sliding fee scale. Context The finding appears to be a systemic problem. Effect Missing applications could indicate that patients who received a sliding fee discount may not have been eligible. Additionally, the sliding fee discount could be applied incorrectly and not in accordance with the Center’s policy. Recommendation We recommend developing proper controls around obtaining and maintaining sliding fee applications, verifying required patient information is present and complete, and apply the sliding fee discount in accordance with written policy. To ensure sliding fee discounts are properly calculated and documented, the Center should increase the frequency of random reviews of its sliding fee discount applications to help detect and correct errors or incomplete applications on a timely basis. In addition, the Center should provide additional training of staff involved in the application of sliding fee discounts. View of responsible officials and planned corrective action. GVHC implemented the physical review and controls described in the 2022 audit response. Our efforts were largely successful as the missing application was the only failure of the physical audit process we put in place. However, a failure of our technology and billing software was revealed. Our plan it to: 1. Continue to provide frequent education and training for front-desk staff to assist in preparation and required completion of the sliding fee applications and proof of income. 2. Continue to identify patients who have exhausted their limited Medicaid benefits and will now qualify for sliding fee scale for dental work. 3. Continue to review reports identifying patients with no end date identified for their sliding fee scale. For identified accounts, determine correct date and enter in the system. 4. Continue 100% audit of all sliding fee scale applications for accuracy of calculation and presence of necessary paperwork. Provide direct feedback to staff when errors are identified. Integrate changes to billing software into the process when sliding fee scales are adjusted and posted. Run reports of sliding fee scale discounts and audit for correct calculation.

Finding 2023-002 Application of Sliding Fee Discount Program Information: Federal Agency U.S. Department of Health and Human Services Federal Assistance Listing Number 93.224 and 93.527 Health Center Program Cluster Award Number H80CS40219 Criteria [X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness OMB 2 CFR 200, Subpart F Compliance Supplement, Part 4, Compliance Requirement N, Special Tests and Provisions states, “Health centers must prepare and apply a sliding fee discount schedule so that the amounts owed for health center services by eligible patients are adjusted (discounted) based on the patient’s ability to pay.” Condition In our testing of 40 sliding fee discounts for health center patients qualifying for reduced charge visits, we identified 1 instance where no application was maintained. We also identified 6 instances where the incorrect sliding fee was applied to the patient. Cause The Center did not have a review process in place to verify eligible patients completed the required application to receive a sliding fee discount and that each application contained the required information. Additionally, the Center did not verify the correct sliding fee discount was based on the Center’s sliding fee scale. Context The finding appears to be a systemic problem. Effect Missing applications could indicate that patients who received a sliding fee discount may not have been eligible. Additionally, the sliding fee discount could be applied incorrectly and not in accordance with the Center’s policy. Recommendation We recommend developing proper controls around obtaining and maintaining sliding fee applications, verifying required patient information is present and complete, and apply the sliding fee discount in accordance with written policy. To ensure sliding fee discounts are properly calculated and documented, the Center should increase the frequency of random reviews of its sliding fee discount applications to help detect and correct errors or incomplete applications on a timely basis. In addition, the Center should provide additional training of staff involved in the application of sliding fee discounts. View of responsible officials and planned corrective action. GVHC implemented the physical review and controls described in the 2022 audit response. Our efforts were largely successful as the missing application was the only failure of the physical audit process we put in place. However, a failure of our technology and billing software was revealed. Our plan it to: 1. Continue to provide frequent education and training for front-desk staff to assist in preparation and required completion of the sliding fee applications and proof of income. 2. Continue to identify patients who have exhausted their limited Medicaid benefits and will now qualify for sliding fee scale for dental work. 3. Continue to review reports identifying patients with no end date identified for their sliding fee scale. For identified accounts, determine correct date and enter in the system. 4. Continue 100% audit of all sliding fee scale applications for accuracy of calculation and presence of necessary paperwork. Provide direct feedback to staff when errors are identified. Integrate changes to billing software into the process when sliding fee scales are adjusted and posted. Run reports of sliding fee scale discounts and audit for correct calculation.

Finding 2023-002 Application of Sliding Fee Discount Program Information: Federal Agency U.S. Department of Health and Human Services Federal Assistance Listing Number 93.224 and 93.527 Health Center Program Cluster Award Number H80CS40219 Criteria [X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness OMB 2 CFR 200, Subpart F Compliance Supplement, Part 4, Compliance Requirement N, Special Tests and Provisions states, “Health centers must prepare and apply a sliding fee discount schedule so that the amounts owed for health center services by eligible patients are adjusted (discounted) based on the patient’s ability to pay.” Condition In our testing of 40 sliding fee discounts for health center patients qualifying for reduced charge visits, we identified 1 instance where no application was maintained. We also identified 6 instances where the incorrect sliding fee was applied to the patient. Cause The Center did not have a review process in place to verify eligible patients completed the required application to receive a sliding fee discount and that each application contained the required information. Additionally, the Center did not verify the correct sliding fee discount was based on the Center’s sliding fee scale. Context The finding appears to be a systemic problem. Effect Missing applications could indicate that patients who received a sliding fee discount may not have been eligible. Additionally, the sliding fee discount could be applied incorrectly and not in accordance with the Center’s policy. Recommendation We recommend developing proper controls around obtaining and maintaining sliding fee applications, verifying required patient information is present and complete, and apply the sliding fee discount in accordance with written policy. To ensure sliding fee discounts are properly calculated and documented, the Center should increase the frequency of random reviews of its sliding fee discount applications to help detect and correct errors or incomplete applications on a timely basis. In addition, the Center should provide additional training of staff involved in the application of sliding fee discounts. View of responsible officials and planned corrective action. GVHC implemented the physical review and controls described in the 2022 audit response. Our efforts were largely successful as the missing application was the only failure of the physical audit process we put in place. However, a failure of our technology and billing software was revealed. Our plan it to: 1. Continue to provide frequent education and training for front-desk staff to assist in preparation and required completion of the sliding fee applications and proof of income. 2. Continue to identify patients who have exhausted their limited Medicaid benefits and will now qualify for sliding fee scale for dental work. 3. Continue to review reports identifying patients with no end date identified for their sliding fee scale. For identified accounts, determine correct date and enter in the system. 4. Continue 100% audit of all sliding fee scale applications for accuracy of calculation and presence of necessary paperwork. Provide direct feedback to staff when errors are identified. Integrate changes to billing software into the process when sliding fee scales are adjusted and posted. Run reports of sliding fee scale discounts and audit for correct calculation.

Finding 2023-002 Application of Sliding Fee Discount Program Information: Federal Agency U.S. Department of Health and Human Services Federal Assistance Listing Number 93.224 and 93.527 Health Center Program Cluster Award Number H80CS40219 Criteria [X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness OMB 2 CFR 200, Subpart F Compliance Supplement, Part 4, Compliance Requirement N, Special Tests and Provisions states, “Health centers must prepare and apply a sliding fee discount schedule so that the amounts owed for health center services by eligible patients are adjusted (discounted) based on the patient’s ability to pay.” Condition In our testing of 40 sliding fee discounts for health center patients qualifying for reduced charge visits, we identified 1 instance where no application was maintained. We also identified 6 instances where the incorrect sliding fee was applied to the patient. Cause The Center did not have a review process in place to verify eligible patients completed the required application to receive a sliding fee discount and that each application contained the required information. Additionally, the Center did not verify the correct sliding fee discount was based on the Center’s sliding fee scale. Context The finding appears to be a systemic problem. Effect Missing applications could indicate that patients who received a sliding fee discount may not have been eligible. Additionally, the sliding fee discount could be applied incorrectly and not in accordance with the Center’s policy. Recommendation We recommend developing proper controls around obtaining and maintaining sliding fee applications, verifying required patient information is present and complete, and apply the sliding fee discount in accordance with written policy. To ensure sliding fee discounts are properly calculated and documented, the Center should increase the frequency of random reviews of its sliding fee discount applications to help detect and correct errors or incomplete applications on a timely basis. In addition, the Center should provide additional training of staff involved in the application of sliding fee discounts. View of responsible officials and planned corrective action. GVHC implemented the physical review and controls described in the 2022 audit response. Our efforts were largely successful as the missing application was the only failure of the physical audit process we put in place. However, a failure of our technology and billing software was revealed. Our plan it to: 1. Continue to provide frequent education and training for front-desk staff to assist in preparation and required completion of the sliding fee applications and proof of income. 2. Continue to identify patients who have exhausted their limited Medicaid benefits and will now qualify for sliding fee scale for dental work. 3. Continue to review reports identifying patients with no end date identified for their sliding fee scale. For identified accounts, determine correct date and enter in the system. 4. Continue 100% audit of all sliding fee scale applications for accuracy of calculation and presence of necessary paperwork. Provide direct feedback to staff when errors are identified. Integrate changes to billing software into the process when sliding fee scales are adjusted and posted. Run reports of sliding fee scale discounts and audit for correct calculation.