Audit 344303

Health Center Program Cluster; CFDA No. 93.224 and 93.527; HHS; grant number H80CS00856; budget periods March 1, 2023, through February 29, 2024. Criteria or specific requirement: Special Tests and Provisions – 42 CFR, Part 56.303(e), (f), and (g). Health Centers receiving funds under the Health Center Program Cluster are required to prepare a schedule of fees or payments for the provision of its services designed to cover its reasonable costs of operation and a corresponding schedule of discounts adjusted on the basis of the patient’s ability to pay, to make every reasonable effort, including the establishment of systems for eligibility determination, billing and collection, and to secure from patient payments for services in accordance with the schedule of fees and discounts. Condition: We noted during our testing of compliance with federal awards that the Health Center did not properly apply the sliding fee discounts approved by the board of directors for 2 patients out of a sample of 25 patients for the year ended February 29, 2024. Questioned cost: None Context: From a total of 6,655 sliding fee discounts for the period, 25 discounts were selected for testing. This sample was not, and was not intended to be, a statistically valid sample. The Health Center’s management did prepare a schedule of discounts adjusted on the basis of the patient’s ability to pay; such schedule was periodically updated and approved by the Health Center’s board of directors and the schedule was uploaded into the Health Center’s billing system. However, there were errors when comparing the approved schedule to certain actual adjustments to patient accounts during the year ended February 29, 2024. For 2 of the 25 accounts selected for testing, the account had an incorrect discount applied. Effect: Discounts were not properly applied to patient accounts. Cause: Errors occurred when analyzing the patient accounts and a full discount occurred when only a portion should have been discounted based on the Health Center’s policy. Identification as a repeat finding, if applicable: Repeat finding. Recommendation: We recommend management work with the billing team and staff to provide additional trainings for those billers applying the slide to patient accounts and conduct additional internal reviews to verify the patient accounts have been adjusted properly.

Health Center Program Cluster; CFDA No. 93.224 and 93.527; HHS; grant number H80CS00856; budget periods March 1, 2023, through February 29, 2024. Criteria or specific requirement: Special Tests and Provisions – 42 CFR, Part 56.303(e), (f), and (g). Health Centers receiving funds under the Health Center Program Cluster are required to prepare a schedule of fees or payments for the provision of its services designed to cover its reasonable costs of operation and a corresponding schedule of discounts adjusted on the basis of the patient’s ability to pay, to make every reasonable effort, including the establishment of systems for eligibility determination, billing and collection, and to secure from patient payments for services in accordance with the schedule of fees and discounts. Condition: We noted during our testing of compliance with federal awards that the Health Center did not properly apply the sliding fee discounts approved by the board of directors for 2 patients out of a sample of 25 patients for the year ended February 29, 2024. Questioned cost: None Context: From a total of 6,655 sliding fee discounts for the period, 25 discounts were selected for testing. This sample was not, and was not intended to be, a statistically valid sample. The Health Center’s management did prepare a schedule of discounts adjusted on the basis of the patient’s ability to pay; such schedule was periodically updated and approved by the Health Center’s board of directors and the schedule was uploaded into the Health Center’s billing system. However, there were errors when comparing the approved schedule to certain actual adjustments to patient accounts during the year ended February 29, 2024. For 2 of the 25 accounts selected for testing, the account had an incorrect discount applied. Effect: Discounts were not properly applied to patient accounts. Cause: Errors occurred when analyzing the patient accounts and a full discount occurred when only a portion should have been discounted based on the Health Center’s policy. Identification as a repeat finding, if applicable: Repeat finding. Recommendation: We recommend management work with the billing team and staff to provide additional trainings for those billers applying the slide to patient accounts and conduct additional internal reviews to verify the patient accounts have been adjusted properly.

Health Center Program Cluster; CFDA No. 93.224 and 93.527; HHS; grant number H80CS00856; budget periods March 1, 2023, through February 29, 2024. Criteria or specific requirement: Special Tests and Provisions – 42 CFR, Part 56.303(e), (f), and (g). Health Centers receiving funds under the Health Center Program Cluster are required to prepare a schedule of fees or payments for the provision of its services designed to cover its reasonable costs of operation and a corresponding schedule of discounts adjusted on the basis of the patient’s ability to pay, to make every reasonable effort, including the establishment of systems for eligibility determination, billing and collection, and to secure from patient payments for services in accordance with the schedule of fees and discounts. Condition: We noted during our testing of compliance with federal awards that the Health Center did not properly apply the sliding fee discounts approved by the board of directors for 2 patients out of a sample of 25 patients for the year ended February 29, 2024. Questioned cost: None Context: From a total of 6,655 sliding fee discounts for the period, 25 discounts were selected for testing. This sample was not, and was not intended to be, a statistically valid sample. The Health Center’s management did prepare a schedule of discounts adjusted on the basis of the patient’s ability to pay; such schedule was periodically updated and approved by the Health Center’s board of directors and the schedule was uploaded into the Health Center’s billing system. However, there were errors when comparing the approved schedule to certain actual adjustments to patient accounts during the year ended February 29, 2024. For 2 of the 25 accounts selected for testing, the account had an incorrect discount applied. Effect: Discounts were not properly applied to patient accounts. Cause: Errors occurred when analyzing the patient accounts and a full discount occurred when only a portion should have been discounted based on the Health Center’s policy. Identification as a repeat finding, if applicable: Repeat finding. Recommendation: We recommend management work with the billing team and staff to provide additional trainings for those billers applying the slide to patient accounts and conduct additional internal reviews to verify the patient accounts have been adjusted properly.

Health Center Program Cluster; CFDA No. 93.224 and 93.527; HHS; grant number H80CS00856; budget periods March 1, 2023, through February 29, 2024. Criteria or specific requirement: Special Tests and Provisions – 42 CFR, Part 56.303(e), (f), and (g). Health Centers receiving funds under the Health Center Program Cluster are required to prepare a schedule of fees or payments for the provision of its services designed to cover its reasonable costs of operation and a corresponding schedule of discounts adjusted on the basis of the patient’s ability to pay, to make every reasonable effort, including the establishment of systems for eligibility determination, billing and collection, and to secure from patient payments for services in accordance with the schedule of fees and discounts. Condition: We noted during our testing of compliance with federal awards that the Health Center did not properly apply the sliding fee discounts approved by the board of directors for 2 patients out of a sample of 25 patients for the year ended February 29, 2024. Questioned cost: None Context: From a total of 6,655 sliding fee discounts for the period, 25 discounts were selected for testing. This sample was not, and was not intended to be, a statistically valid sample. The Health Center’s management did prepare a schedule of discounts adjusted on the basis of the patient’s ability to pay; such schedule was periodically updated and approved by the Health Center’s board of directors and the schedule was uploaded into the Health Center’s billing system. However, there were errors when comparing the approved schedule to certain actual adjustments to patient accounts during the year ended February 29, 2024. For 2 of the 25 accounts selected for testing, the account had an incorrect discount applied. Effect: Discounts were not properly applied to patient accounts. Cause: Errors occurred when analyzing the patient accounts and a full discount occurred when only a portion should have been discounted based on the Health Center’s policy. Identification as a repeat finding, if applicable: Repeat finding. Recommendation: We recommend management work with the billing team and staff to provide additional trainings for those billers applying the slide to patient accounts and conduct additional internal reviews to verify the patient accounts have been adjusted properly.