FAC Explorer

Audit 362000

FY End
2024-11-30
Total Expended
$14.09M
Findings
10
Programs
9
Organization: Stigler Health and Wellness Center, Inc. (OK)
Year: 2024 Accepted: 2025-07-11
Auditor: Forvis Mazars LLP

Organization Exclusion Status:

Findings

ID Ref Severity Repeat Requirement
571121 2024-001 Significant Deficiency - N
571122 2024-001 Significant Deficiency - N
571123 2024-001 Significant Deficiency - N
571124 2024-001 Significant Deficiency - N
571125 2024-002 Significant Deficiency - L
1147563 2024-001 Significant Deficiency - N
1147564 2024-001 Significant Deficiency - N
1147565 2024-001 Significant Deficiency - N
1147566 2024-001 Significant Deficiency - N
1147567 2024-002 Significant Deficiency - L

Programs

ALN Program Spent Major Findings
93.600 Head Start $7.94M Yes 0
21.027 Coronavirus State and Local Fiscal Recovery Funds $765,930 Yes 1
10.558 Child and Adult Care Food Program $308,732 - 0
93.526 Grants for Capital Development in Health Centers $127,121 - 0
93.224 Health Center Program (community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) $87,641 Yes 1
93.527 Grants for New and Expanded Services Under the Health Center Program $65,059 Yes 1
93.788 Opioid Str $32,417 - 0
93.243 Substance Abuse and Mental Health Services Projects of Regional and National Significance $18,627 - 0
93.959 Block Grants for Prevention and Treatment of Substance Abuse $459 - 0

Contacts

Name Title Type
VTA9YVH8P637 Stephanie Long Auditee
9189673368 Ally Jackson Auditor
No contacts on file

Notes to SEFA

Title: Note 1. Basis of Presentation Accounting Policies: Expenditures reported on the Schedule are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Negative amounts shown on the Schedule, if any, represent adjustments or credits made in the normal course of business to amounts reported as expenditures in prior years. De Minimis Rate Used: N Rate Explanation: Stigler Health and Wellness Center, Inc. has elected not to use the 10% de minimis indirect cost rate allowed under the Uniform Guidance. The accompanying schedule of expenditures of federal awards (the “Schedule”) includes the federal award activity of Stigler Health and Wellness Center, Inc, under programs of the federal government for the year ended November 30, 2024. The information in this Schedule is presented in accordance with the requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Because the schedule presents only a selected portion of the operations of Stigler Health and Wellness Center, Inc, it is not intended to and does not present the financial position, results of operations, changes in net assets, or cash flows of Stigler Health and Wellness Center, Inc.
Title: Note 4. Federal Loan Programs Accounting Policies: Expenditures reported on the Schedule are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Negative amounts shown on the Schedule, if any, represent adjustments or credits made in the normal course of business to amounts reported as expenditures in prior years. De Minimis Rate Used: N Rate Explanation: Stigler Health and Wellness Center, Inc. has elected not to use the 10% de minimis indirect cost rate allowed under the Uniform Guidance. Stigler Health and Wellness Center, Inc. did not have any federal loan programs during the year ended November 30, 2024.

Finding Details

Finding 2024-001
Health Center Program Cluster – Assistance Listing Numbers 93.224 and 93.527 U.S. Department of Health and Human Services Award No. 6 H80CS04286-19, April 1, 2023 – March 31, 2024 Award No. 6 H80CS04286‐20, April 1, 2024 – March 31, 2025 Award No. 6 H8FCS41015‐01, April 1, 2021 – March 31, 2024 Award No. 6 H8GCS47983‐01, December 1, 2022 – December 31, 2023 Award No. 5 H8HCSHealth Center Program Cluster – Assistance Listing Numbers 93.224 and 93.527 U.S. Department of Health and Human Services Award No. 6 H80CS04286-19, April 1, 2023 – March 31, 2024 Award No. 6 H80CS04286-20, April 1, 2024 – March 31, 2025 Award No. 6 H8FCS41015-01, April 1, 2021 – March 31, 2024 Award No. 6 H8GCS47983-01, December 1, 2022 – December 31, 2023 Award No. 5 H8HCS45036-02, September 1, 2022 – August 31, 2023 Award No. 1 H8ICS46994-01, September 1, 2022 – August 31, 2024 Award No. 1 H8LCS51874-01, September 1, 2023 – December 31, 2024 Criteria or Specific Requirement – Special Tests and Provisions: Sliding Fee Discounts (42 USC 254(k)(3)(g); 42 CFR sections 51c.303(g); and 42 CFR sections 56.303 (f)) Condition – Sliding fee discounts applied to patient charges were inconsistent with the Organization’s sliding fee discount schedule. The Organization’s sliding fee discount policy is not compliant with the Health Center Compliance Manual for dispense fees of its in-house pharmacies, which are within the scope of the Health Center Program. Cause – The Organization did not comply with its sliding fee discount policy. The Organization also expanded it’s in-house pharmacy services in recent years without ensuring the informal policy and information system were set up in compliance with the Health Center Compliance Manual. Effect or potential effect – The patients’ responsibility for services rendered by the Organization was inconsistent with the sliding fee discount schedules. Additionally, the Organization’s sliding fee discount schedules for in-house pharmacy dispense fees did not contain the required number of categories between 100% and 200% of the federal poverty levels (FPL) or differentiate dispense fees based on FPL for certain prescription drugs. Further, not all patients of the Organization’s in-house pharmacies were given the opportunity for the sliding fee discount program. Questioned costs – None Context – The population of sliding fee discounts was stratified between in-house pharmacy dispense fees and all other in-scope services of the Organization. A sample of 25 prescriptions were tested out of a population of approximately 52,000 prescriptions dispensed through the in-house pharmacies and 7 instances of inappropriate sliding fee discounts were identified. A sample of 25 encounters were tested out of the population of approximately 146,000 encounters for all other inscope services and 2 instances of inappropriate sliding fee discounts were identified. The sampling methodology used is not and is not intended to be statistically valid. Additionally, the Organization’s informal policy for sliding fee discounts of in-house pharmacy dispense fees contains 2 categories instead of the minimum of 3 between 100% and 200% of the FPL. The Organization also maintains 2 lists of prescription drugs that are dispensed for a flat dispensing fee if covered under the 340B program, rather than applying discounts based on the patient’s ability to pay. Finally, the Organization only offers sliding fee discounts on prescriptions that also qualify under the 340B program. Identification as a repeat finding, if applicable – No. Recommendation – The Organization should review the sliding fee discount policy and schedules to ensure compliance with the Health Center Program Compliance Manual for all services within the scope of the program while considering improvements that can be made to improve compliance with the policy and schedules and increased accuracy of system-generated adjustments. The Organization should also continue educating personnel on the sliding fee discount program and consider implementing internal audits of sliding fee discounts to monitor and identify specific areas for further improvements or training.
Finding 2024-001
Health Center Program Cluster – Assistance Listing Numbers 93.224 and 93.527 U.S. Department of Health and Human Services Award No. 6 H80CS04286-19, April 1, 2023 – March 31, 2024 Award No. 6 H80CS04286‐20, April 1, 2024 – March 31, 2025 Award No. 6 H8FCS41015‐01, April 1, 2021 – March 31, 2024 Award No. 6 H8GCS47983‐01, December 1, 2022 – December 31, 2023 Award No. 5 H8HCSHealth Center Program Cluster – Assistance Listing Numbers 93.224 and 93.527 U.S. Department of Health and Human Services Award No. 6 H80CS04286-19, April 1, 2023 – March 31, 2024 Award No. 6 H80CS04286-20, April 1, 2024 – March 31, 2025 Award No. 6 H8FCS41015-01, April 1, 2021 – March 31, 2024 Award No. 6 H8GCS47983-01, December 1, 2022 – December 31, 2023 Award No. 5 H8HCS45036-02, September 1, 2022 – August 31, 2023 Award No. 1 H8ICS46994-01, September 1, 2022 – August 31, 2024 Award No. 1 H8LCS51874-01, September 1, 2023 – December 31, 2024 Criteria or Specific Requirement – Special Tests and Provisions: Sliding Fee Discounts (42 USC 254(k)(3)(g); 42 CFR sections 51c.303(g); and 42 CFR sections 56.303 (f)) Condition – Sliding fee discounts applied to patient charges were inconsistent with the Organization’s sliding fee discount schedule. The Organization’s sliding fee discount policy is not compliant with the Health Center Compliance Manual for dispense fees of its in-house pharmacies, which are within the scope of the Health Center Program. Cause – The Organization did not comply with its sliding fee discount policy. The Organization also expanded it’s in-house pharmacy services in recent years without ensuring the informal policy and information system were set up in compliance with the Health Center Compliance Manual. Effect or potential effect – The patients’ responsibility for services rendered by the Organization was inconsistent with the sliding fee discount schedules. Additionally, the Organization’s sliding fee discount schedules for in-house pharmacy dispense fees did not contain the required number of categories between 100% and 200% of the federal poverty levels (FPL) or differentiate dispense fees based on FPL for certain prescription drugs. Further, not all patients of the Organization’s in-house pharmacies were given the opportunity for the sliding fee discount program. Questioned costs – None Context – The population of sliding fee discounts was stratified between in-house pharmacy dispense fees and all other in-scope services of the Organization. A sample of 25 prescriptions were tested out of a population of approximately 52,000 prescriptions dispensed through the in-house pharmacies and 7 instances of inappropriate sliding fee discounts were identified. A sample of 25 encounters were tested out of the population of approximately 146,000 encounters for all other inscope services and 2 instances of inappropriate sliding fee discounts were identified. The sampling methodology used is not and is not intended to be statistically valid. Additionally, the Organization’s informal policy for sliding fee discounts of in-house pharmacy dispense fees contains 2 categories instead of the minimum of 3 between 100% and 200% of the FPL. The Organization also maintains 2 lists of prescription drugs that are dispensed for a flat dispensing fee if covered under the 340B program, rather than applying discounts based on the patient’s ability to pay. Finally, the Organization only offers sliding fee discounts on prescriptions that also qualify under the 340B program. Identification as a repeat finding, if applicable – No. Recommendation – The Organization should review the sliding fee discount policy and schedules to ensure compliance with the Health Center Program Compliance Manual for all services within the scope of the program while considering improvements that can be made to improve compliance with the policy and schedules and increased accuracy of system-generated adjustments. The Organization should also continue educating personnel on the sliding fee discount program and consider implementing internal audits of sliding fee discounts to monitor and identify specific areas for further improvements or training.
Finding 2024-001
Health Center Program Cluster – Assistance Listing Numbers 93.224 and 93.527 U.S. Department of Health and Human Services Award No. 6 H80CS04286-19, April 1, 2023 – March 31, 2024 Award No. 6 H80CS04286‐20, April 1, 2024 – March 31, 2025 Award No. 6 H8FCS41015‐01, April 1, 2021 – March 31, 2024 Award No. 6 H8GCS47983‐01, December 1, 2022 – December 31, 2023 Award No. 5 H8HCSHealth Center Program Cluster – Assistance Listing Numbers 93.224 and 93.527 U.S. Department of Health and Human Services Award No. 6 H80CS04286-19, April 1, 2023 – March 31, 2024 Award No. 6 H80CS04286-20, April 1, 2024 – March 31, 2025 Award No. 6 H8FCS41015-01, April 1, 2021 – March 31, 2024 Award No. 6 H8GCS47983-01, December 1, 2022 – December 31, 2023 Award No. 5 H8HCS45036-02, September 1, 2022 – August 31, 2023 Award No. 1 H8ICS46994-01, September 1, 2022 – August 31, 2024 Award No. 1 H8LCS51874-01, September 1, 2023 – December 31, 2024 Criteria or Specific Requirement – Special Tests and Provisions: Sliding Fee Discounts (42 USC 254(k)(3)(g); 42 CFR sections 51c.303(g); and 42 CFR sections 56.303 (f)) Condition – Sliding fee discounts applied to patient charges were inconsistent with the Organization’s sliding fee discount schedule. The Organization’s sliding fee discount policy is not compliant with the Health Center Compliance Manual for dispense fees of its in-house pharmacies, which are within the scope of the Health Center Program. Cause – The Organization did not comply with its sliding fee discount policy. The Organization also expanded it’s in-house pharmacy services in recent years without ensuring the informal policy and information system were set up in compliance with the Health Center Compliance Manual. Effect or potential effect – The patients’ responsibility for services rendered by the Organization was inconsistent with the sliding fee discount schedules. Additionally, the Organization’s sliding fee discount schedules for in-house pharmacy dispense fees did not contain the required number of categories between 100% and 200% of the federal poverty levels (FPL) or differentiate dispense fees based on FPL for certain prescription drugs. Further, not all patients of the Organization’s in-house pharmacies were given the opportunity for the sliding fee discount program. Questioned costs – None Context – The population of sliding fee discounts was stratified between in-house pharmacy dispense fees and all other in-scope services of the Organization. A sample of 25 prescriptions were tested out of a population of approximately 52,000 prescriptions dispensed through the in-house pharmacies and 7 instances of inappropriate sliding fee discounts were identified. A sample of 25 encounters were tested out of the population of approximately 146,000 encounters for all other inscope services and 2 instances of inappropriate sliding fee discounts were identified. The sampling methodology used is not and is not intended to be statistically valid. Additionally, the Organization’s informal policy for sliding fee discounts of in-house pharmacy dispense fees contains 2 categories instead of the minimum of 3 between 100% and 200% of the FPL. The Organization also maintains 2 lists of prescription drugs that are dispensed for a flat dispensing fee if covered under the 340B program, rather than applying discounts based on the patient’s ability to pay. Finally, the Organization only offers sliding fee discounts on prescriptions that also qualify under the 340B program. Identification as a repeat finding, if applicable – No. Recommendation – The Organization should review the sliding fee discount policy and schedules to ensure compliance with the Health Center Program Compliance Manual for all services within the scope of the program while considering improvements that can be made to improve compliance with the policy and schedules and increased accuracy of system-generated adjustments. The Organization should also continue educating personnel on the sliding fee discount program and consider implementing internal audits of sliding fee discounts to monitor and identify specific areas for further improvements or training.
Finding 2024-001
Health Center Program Cluster – Assistance Listing Numbers 93.224 and 93.527 U.S. Department of Health and Human Services Award No. 6 H80CS04286-19, April 1, 2023 – March 31, 2024 Award No. 6 H80CS04286‐20, April 1, 2024 – March 31, 2025 Award No. 6 H8FCS41015‐01, April 1, 2021 – March 31, 2024 Award No. 6 H8GCS47983‐01, December 1, 2022 – December 31, 2023 Award No. 5 H8HCSHealth Center Program Cluster – Assistance Listing Numbers 93.224 and 93.527 U.S. Department of Health and Human Services Award No. 6 H80CS04286-19, April 1, 2023 – March 31, 2024 Award No. 6 H80CS04286-20, April 1, 2024 – March 31, 2025 Award No. 6 H8FCS41015-01, April 1, 2021 – March 31, 2024 Award No. 6 H8GCS47983-01, December 1, 2022 – December 31, 2023 Award No. 5 H8HCS45036-02, September 1, 2022 – August 31, 2023 Award No. 1 H8ICS46994-01, September 1, 2022 – August 31, 2024 Award No. 1 H8LCS51874-01, September 1, 2023 – December 31, 2024 Criteria or Specific Requirement – Special Tests and Provisions: Sliding Fee Discounts (42 USC 254(k)(3)(g); 42 CFR sections 51c.303(g); and 42 CFR sections 56.303 (f)) Condition – Sliding fee discounts applied to patient charges were inconsistent with the Organization’s sliding fee discount schedule. The Organization’s sliding fee discount policy is not compliant with the Health Center Compliance Manual for dispense fees of its in-house pharmacies, which are within the scope of the Health Center Program. Cause – The Organization did not comply with its sliding fee discount policy. The Organization also expanded it’s in-house pharmacy services in recent years without ensuring the informal policy and information system were set up in compliance with the Health Center Compliance Manual. Effect or potential effect – The patients’ responsibility for services rendered by the Organization was inconsistent with the sliding fee discount schedules. Additionally, the Organization’s sliding fee discount schedules for in-house pharmacy dispense fees did not contain the required number of categories between 100% and 200% of the federal poverty levels (FPL) or differentiate dispense fees based on FPL for certain prescription drugs. Further, not all patients of the Organization’s in-house pharmacies were given the opportunity for the sliding fee discount program. Questioned costs – None Context – The population of sliding fee discounts was stratified between in-house pharmacy dispense fees and all other in-scope services of the Organization. A sample of 25 prescriptions were tested out of a population of approximately 52,000 prescriptions dispensed through the in-house pharmacies and 7 instances of inappropriate sliding fee discounts were identified. A sample of 25 encounters were tested out of the population of approximately 146,000 encounters for all other inscope services and 2 instances of inappropriate sliding fee discounts were identified. The sampling methodology used is not and is not intended to be statistically valid. Additionally, the Organization’s informal policy for sliding fee discounts of in-house pharmacy dispense fees contains 2 categories instead of the minimum of 3 between 100% and 200% of the FPL. The Organization also maintains 2 lists of prescription drugs that are dispensed for a flat dispensing fee if covered under the 340B program, rather than applying discounts based on the patient’s ability to pay. Finally, the Organization only offers sliding fee discounts on prescriptions that also qualify under the 340B program. Identification as a repeat finding, if applicable – No. Recommendation – The Organization should review the sliding fee discount policy and schedules to ensure compliance with the Health Center Program Compliance Manual for all services within the scope of the program while considering improvements that can be made to improve compliance with the policy and schedules and increased accuracy of system-generated adjustments. The Organization should also continue educating personnel on the sliding fee discount program and consider implementing internal audits of sliding fee discounts to monitor and identify specific areas for further improvements or training.
Finding 2024-002
Coronavirus State and Local Fiscal Recovery Funds – Assistance Lising No. 21.027 U.S Department of Treasury Oklahoma State Department of Health Criteria or Specific Requirement – Reporting (2 CFR 200.329) Condition – The Organization’s internal controls over compliance were not able to ensure progress reporting required to be submitted to the pass-through entity was completed timely. Cause – The Organization does not have internal controls over compliance in place to ensure all grant reporting requirements are satisfied timely. Effect or potential effect – The Organization did not submit the required quarterly progress reports in a timely manner. Questioned costs – None Context – The Organization is required to submit quarterly progress reports to the pass-through entity in a timely manner. Identification as a repeat finding, if applicable – No. Recommendation – The Organization should consider implementing a grant reporting calendar for all grants with reporting requirements.
Finding 2024-001
Health Center Program Cluster – Assistance Listing Numbers 93.224 and 93.527 U.S. Department of Health and Human Services Award No. 6 H80CS04286-19, April 1, 2023 – March 31, 2024 Award No. 6 H80CS04286‐20, April 1, 2024 – March 31, 2025 Award No. 6 H8FCS41015‐01, April 1, 2021 – March 31, 2024 Award No. 6 H8GCS47983‐01, December 1, 2022 – December 31, 2023 Award No. 5 H8HCSHealth Center Program Cluster – Assistance Listing Numbers 93.224 and 93.527 U.S. Department of Health and Human Services Award No. 6 H80CS04286-19, April 1, 2023 – March 31, 2024 Award No. 6 H80CS04286-20, April 1, 2024 – March 31, 2025 Award No. 6 H8FCS41015-01, April 1, 2021 – March 31, 2024 Award No. 6 H8GCS47983-01, December 1, 2022 – December 31, 2023 Award No. 5 H8HCS45036-02, September 1, 2022 – August 31, 2023 Award No. 1 H8ICS46994-01, September 1, 2022 – August 31, 2024 Award No. 1 H8LCS51874-01, September 1, 2023 – December 31, 2024 Criteria or Specific Requirement – Special Tests and Provisions: Sliding Fee Discounts (42 USC 254(k)(3)(g); 42 CFR sections 51c.303(g); and 42 CFR sections 56.303 (f)) Condition – Sliding fee discounts applied to patient charges were inconsistent with the Organization’s sliding fee discount schedule. The Organization’s sliding fee discount policy is not compliant with the Health Center Compliance Manual for dispense fees of its in-house pharmacies, which are within the scope of the Health Center Program. Cause – The Organization did not comply with its sliding fee discount policy. The Organization also expanded it’s in-house pharmacy services in recent years without ensuring the informal policy and information system were set up in compliance with the Health Center Compliance Manual. Effect or potential effect – The patients’ responsibility for services rendered by the Organization was inconsistent with the sliding fee discount schedules. Additionally, the Organization’s sliding fee discount schedules for in-house pharmacy dispense fees did not contain the required number of categories between 100% and 200% of the federal poverty levels (FPL) or differentiate dispense fees based on FPL for certain prescription drugs. Further, not all patients of the Organization’s in-house pharmacies were given the opportunity for the sliding fee discount program. Questioned costs – None Context – The population of sliding fee discounts was stratified between in-house pharmacy dispense fees and all other in-scope services of the Organization. A sample of 25 prescriptions were tested out of a population of approximately 52,000 prescriptions dispensed through the in-house pharmacies and 7 instances of inappropriate sliding fee discounts were identified. A sample of 25 encounters were tested out of the population of approximately 146,000 encounters for all other inscope services and 2 instances of inappropriate sliding fee discounts were identified. The sampling methodology used is not and is not intended to be statistically valid. Additionally, the Organization’s informal policy for sliding fee discounts of in-house pharmacy dispense fees contains 2 categories instead of the minimum of 3 between 100% and 200% of the FPL. The Organization also maintains 2 lists of prescription drugs that are dispensed for a flat dispensing fee if covered under the 340B program, rather than applying discounts based on the patient’s ability to pay. Finally, the Organization only offers sliding fee discounts on prescriptions that also qualify under the 340B program. Identification as a repeat finding, if applicable – No. Recommendation – The Organization should review the sliding fee discount policy and schedules to ensure compliance with the Health Center Program Compliance Manual for all services within the scope of the program while considering improvements that can be made to improve compliance with the policy and schedules and increased accuracy of system-generated adjustments. The Organization should also continue educating personnel on the sliding fee discount program and consider implementing internal audits of sliding fee discounts to monitor and identify specific areas for further improvements or training.
Finding 2024-001
Health Center Program Cluster – Assistance Listing Numbers 93.224 and 93.527 U.S. Department of Health and Human Services Award No. 6 H80CS04286-19, April 1, 2023 – March 31, 2024 Award No. 6 H80CS04286‐20, April 1, 2024 – March 31, 2025 Award No. 6 H8FCS41015‐01, April 1, 2021 – March 31, 2024 Award No. 6 H8GCS47983‐01, December 1, 2022 – December 31, 2023 Award No. 5 H8HCSHealth Center Program Cluster – Assistance Listing Numbers 93.224 and 93.527 U.S. Department of Health and Human Services Award No. 6 H80CS04286-19, April 1, 2023 – March 31, 2024 Award No. 6 H80CS04286-20, April 1, 2024 – March 31, 2025 Award No. 6 H8FCS41015-01, April 1, 2021 – March 31, 2024 Award No. 6 H8GCS47983-01, December 1, 2022 – December 31, 2023 Award No. 5 H8HCS45036-02, September 1, 2022 – August 31, 2023 Award No. 1 H8ICS46994-01, September 1, 2022 – August 31, 2024 Award No. 1 H8LCS51874-01, September 1, 2023 – December 31, 2024 Criteria or Specific Requirement – Special Tests and Provisions: Sliding Fee Discounts (42 USC 254(k)(3)(g); 42 CFR sections 51c.303(g); and 42 CFR sections 56.303 (f)) Condition – Sliding fee discounts applied to patient charges were inconsistent with the Organization’s sliding fee discount schedule. The Organization’s sliding fee discount policy is not compliant with the Health Center Compliance Manual for dispense fees of its in-house pharmacies, which are within the scope of the Health Center Program. Cause – The Organization did not comply with its sliding fee discount policy. The Organization also expanded it’s in-house pharmacy services in recent years without ensuring the informal policy and information system were set up in compliance with the Health Center Compliance Manual. Effect or potential effect – The patients’ responsibility for services rendered by the Organization was inconsistent with the sliding fee discount schedules. Additionally, the Organization’s sliding fee discount schedules for in-house pharmacy dispense fees did not contain the required number of categories between 100% and 200% of the federal poverty levels (FPL) or differentiate dispense fees based on FPL for certain prescription drugs. Further, not all patients of the Organization’s in-house pharmacies were given the opportunity for the sliding fee discount program. Questioned costs – None Context – The population of sliding fee discounts was stratified between in-house pharmacy dispense fees and all other in-scope services of the Organization. A sample of 25 prescriptions were tested out of a population of approximately 52,000 prescriptions dispensed through the in-house pharmacies and 7 instances of inappropriate sliding fee discounts were identified. A sample of 25 encounters were tested out of the population of approximately 146,000 encounters for all other inscope services and 2 instances of inappropriate sliding fee discounts were identified. The sampling methodology used is not and is not intended to be statistically valid. Additionally, the Organization’s informal policy for sliding fee discounts of in-house pharmacy dispense fees contains 2 categories instead of the minimum of 3 between 100% and 200% of the FPL. The Organization also maintains 2 lists of prescription drugs that are dispensed for a flat dispensing fee if covered under the 340B program, rather than applying discounts based on the patient’s ability to pay. Finally, the Organization only offers sliding fee discounts on prescriptions that also qualify under the 340B program. Identification as a repeat finding, if applicable – No. Recommendation – The Organization should review the sliding fee discount policy and schedules to ensure compliance with the Health Center Program Compliance Manual for all services within the scope of the program while considering improvements that can be made to improve compliance with the policy and schedules and increased accuracy of system-generated adjustments. The Organization should also continue educating personnel on the sliding fee discount program and consider implementing internal audits of sliding fee discounts to monitor and identify specific areas for further improvements or training.
Finding 2024-001
Health Center Program Cluster – Assistance Listing Numbers 93.224 and 93.527 U.S. Department of Health and Human Services Award No. 6 H80CS04286-19, April 1, 2023 – March 31, 2024 Award No. 6 H80CS04286‐20, April 1, 2024 – March 31, 2025 Award No. 6 H8FCS41015‐01, April 1, 2021 – March 31, 2024 Award No. 6 H8GCS47983‐01, December 1, 2022 – December 31, 2023 Award No. 5 H8HCSHealth Center Program Cluster – Assistance Listing Numbers 93.224 and 93.527 U.S. Department of Health and Human Services Award No. 6 H80CS04286-19, April 1, 2023 – March 31, 2024 Award No. 6 H80CS04286-20, April 1, 2024 – March 31, 2025 Award No. 6 H8FCS41015-01, April 1, 2021 – March 31, 2024 Award No. 6 H8GCS47983-01, December 1, 2022 – December 31, 2023 Award No. 5 H8HCS45036-02, September 1, 2022 – August 31, 2023 Award No. 1 H8ICS46994-01, September 1, 2022 – August 31, 2024 Award No. 1 H8LCS51874-01, September 1, 2023 – December 31, 2024 Criteria or Specific Requirement – Special Tests and Provisions: Sliding Fee Discounts (42 USC 254(k)(3)(g); 42 CFR sections 51c.303(g); and 42 CFR sections 56.303 (f)) Condition – Sliding fee discounts applied to patient charges were inconsistent with the Organization’s sliding fee discount schedule. The Organization’s sliding fee discount policy is not compliant with the Health Center Compliance Manual for dispense fees of its in-house pharmacies, which are within the scope of the Health Center Program. Cause – The Organization did not comply with its sliding fee discount policy. The Organization also expanded it’s in-house pharmacy services in recent years without ensuring the informal policy and information system were set up in compliance with the Health Center Compliance Manual. Effect or potential effect – The patients’ responsibility for services rendered by the Organization was inconsistent with the sliding fee discount schedules. Additionally, the Organization’s sliding fee discount schedules for in-house pharmacy dispense fees did not contain the required number of categories between 100% and 200% of the federal poverty levels (FPL) or differentiate dispense fees based on FPL for certain prescription drugs. Further, not all patients of the Organization’s in-house pharmacies were given the opportunity for the sliding fee discount program. Questioned costs – None Context – The population of sliding fee discounts was stratified between in-house pharmacy dispense fees and all other in-scope services of the Organization. A sample of 25 prescriptions were tested out of a population of approximately 52,000 prescriptions dispensed through the in-house pharmacies and 7 instances of inappropriate sliding fee discounts were identified. A sample of 25 encounters were tested out of the population of approximately 146,000 encounters for all other inscope services and 2 instances of inappropriate sliding fee discounts were identified. The sampling methodology used is not and is not intended to be statistically valid. Additionally, the Organization’s informal policy for sliding fee discounts of in-house pharmacy dispense fees contains 2 categories instead of the minimum of 3 between 100% and 200% of the FPL. The Organization also maintains 2 lists of prescription drugs that are dispensed for a flat dispensing fee if covered under the 340B program, rather than applying discounts based on the patient’s ability to pay. Finally, the Organization only offers sliding fee discounts on prescriptions that also qualify under the 340B program. Identification as a repeat finding, if applicable – No. Recommendation – The Organization should review the sliding fee discount policy and schedules to ensure compliance with the Health Center Program Compliance Manual for all services within the scope of the program while considering improvements that can be made to improve compliance with the policy and schedules and increased accuracy of system-generated adjustments. The Organization should also continue educating personnel on the sliding fee discount program and consider implementing internal audits of sliding fee discounts to monitor and identify specific areas for further improvements or training.
Finding 2024-001
Health Center Program Cluster – Assistance Listing Numbers 93.224 and 93.527 U.S. Department of Health and Human Services Award No. 6 H80CS04286-19, April 1, 2023 – March 31, 2024 Award No. 6 H80CS04286‐20, April 1, 2024 – March 31, 2025 Award No. 6 H8FCS41015‐01, April 1, 2021 – March 31, 2024 Award No. 6 H8GCS47983‐01, December 1, 2022 – December 31, 2023 Award No. 5 H8HCSHealth Center Program Cluster – Assistance Listing Numbers 93.224 and 93.527 U.S. Department of Health and Human Services Award No. 6 H80CS04286-19, April 1, 2023 – March 31, 2024 Award No. 6 H80CS04286-20, April 1, 2024 – March 31, 2025 Award No. 6 H8FCS41015-01, April 1, 2021 – March 31, 2024 Award No. 6 H8GCS47983-01, December 1, 2022 – December 31, 2023 Award No. 5 H8HCS45036-02, September 1, 2022 – August 31, 2023 Award No. 1 H8ICS46994-01, September 1, 2022 – August 31, 2024 Award No. 1 H8LCS51874-01, September 1, 2023 – December 31, 2024 Criteria or Specific Requirement – Special Tests and Provisions: Sliding Fee Discounts (42 USC 254(k)(3)(g); 42 CFR sections 51c.303(g); and 42 CFR sections 56.303 (f)) Condition – Sliding fee discounts applied to patient charges were inconsistent with the Organization’s sliding fee discount schedule. The Organization’s sliding fee discount policy is not compliant with the Health Center Compliance Manual for dispense fees of its in-house pharmacies, which are within the scope of the Health Center Program. Cause – The Organization did not comply with its sliding fee discount policy. The Organization also expanded it’s in-house pharmacy services in recent years without ensuring the informal policy and information system were set up in compliance with the Health Center Compliance Manual. Effect or potential effect – The patients’ responsibility for services rendered by the Organization was inconsistent with the sliding fee discount schedules. Additionally, the Organization’s sliding fee discount schedules for in-house pharmacy dispense fees did not contain the required number of categories between 100% and 200% of the federal poverty levels (FPL) or differentiate dispense fees based on FPL for certain prescription drugs. Further, not all patients of the Organization’s in-house pharmacies were given the opportunity for the sliding fee discount program. Questioned costs – None Context – The population of sliding fee discounts was stratified between in-house pharmacy dispense fees and all other in-scope services of the Organization. A sample of 25 prescriptions were tested out of a population of approximately 52,000 prescriptions dispensed through the in-house pharmacies and 7 instances of inappropriate sliding fee discounts were identified. A sample of 25 encounters were tested out of the population of approximately 146,000 encounters for all other inscope services and 2 instances of inappropriate sliding fee discounts were identified. The sampling methodology used is not and is not intended to be statistically valid. Additionally, the Organization’s informal policy for sliding fee discounts of in-house pharmacy dispense fees contains 2 categories instead of the minimum of 3 between 100% and 200% of the FPL. The Organization also maintains 2 lists of prescription drugs that are dispensed for a flat dispensing fee if covered under the 340B program, rather than applying discounts based on the patient’s ability to pay. Finally, the Organization only offers sliding fee discounts on prescriptions that also qualify under the 340B program. Identification as a repeat finding, if applicable – No. Recommendation – The Organization should review the sliding fee discount policy and schedules to ensure compliance with the Health Center Program Compliance Manual for all services within the scope of the program while considering improvements that can be made to improve compliance with the policy and schedules and increased accuracy of system-generated adjustments. The Organization should also continue educating personnel on the sliding fee discount program and consider implementing internal audits of sliding fee discounts to monitor and identify specific areas for further improvements or training.
Finding 2024-002
Coronavirus State and Local Fiscal Recovery Funds – Assistance Lising No. 21.027 U.S Department of Treasury Oklahoma State Department of Health Criteria or Specific Requirement – Reporting (2 CFR 200.329) Condition – The Organization’s internal controls over compliance were not able to ensure progress reporting required to be submitted to the pass-through entity was completed timely. Cause – The Organization does not have internal controls over compliance in place to ensure all grant reporting requirements are satisfied timely. Effect or potential effect – The Organization did not submit the required quarterly progress reports in a timely manner. Questioned costs – None Context – The Organization is required to submit quarterly progress reports to the pass-through entity in a timely manner. Identification as a repeat finding, if applicable – No. Recommendation – The Organization should consider implementing a grant reporting calendar for all grants with reporting requirements.