Audit 365353

2024 – 001 Federal Agency: U.S Department of Health and Human Services Federal Program Title: Consolidated Health Centers Assistance Listing Numbers: 93.224/93.527 Award Period: 3/1/23 – 2/28/24 and 3/1/24 – 2/28/25 Type of Finding: • Significant Deficiency in Internal Control over Compliance Criteria or Specific Requirement: Per Title 42 Chapter 1 Subchapter D Section 51c303(f), “Health centers must have a schedule of fees or payments for the provision of their health services consistent with locally prevailing rates or charges designed to cover their reasonable costs of operation. They are also required to have a corresponding schedule of discounts applied and adjusted on the basis of the patient’s ability to pay.” Condition: During our testing of sliding fee discounts for health center patients qualifying for reduced charge visits, we identified one encounter where the sliding fee discount was calculated properly on the sliding fee application, but applied incorrectly to the patient account. Questioned costs: None. Context: The patient intake process occurred according to policy and a 20% adjustment was determined based on family size and income level. When the discount was applied to the patient's accounts, a manual error was made and the discount was applied at 100%. Cause: Manual error entering the patient discount in the electronic medical record system. Effect: Individual received a larger discount than should have been provided according to policy. In addition, without sufficient internal control and review processes in place, there is a greater risk of additional errors occurring. Recommendation: We recommend the Organization investigate the underlying cause of the error, and provide education or incorporate some sort of reconciliation or review process to ensure sliding fee adjustments applied match the original determination. View of responsible officials: No disagreement with the finding. Management will provide training to individuals involved with entering sliding fee discounts into EMR and will investigate other review or reconciliation procedures that could be incorporated to reduce risk.

2024 – 001 Federal Agency: U.S Department of Health and Human Services Federal Program Title: Consolidated Health Centers Assistance Listing Numbers: 93.224/93.527 Award Period: 3/1/23 – 2/28/24 and 3/1/24 – 2/28/25 Type of Finding: • Significant Deficiency in Internal Control over Compliance Criteria or Specific Requirement: Per Title 42 Chapter 1 Subchapter D Section 51c303(f), “Health centers must have a schedule of fees or payments for the provision of their health services consistent with locally prevailing rates or charges designed to cover their reasonable costs of operation. They are also required to have a corresponding schedule of discounts applied and adjusted on the basis of the patient’s ability to pay.” Condition: During our testing of sliding fee discounts for health center patients qualifying for reduced charge visits, we identified one encounter where the sliding fee discount was calculated properly on the sliding fee application, but applied incorrectly to the patient account. Questioned costs: None. Context: The patient intake process occurred according to policy and a 20% adjustment was determined based on family size and income level. When the discount was applied to the patient's accounts, a manual error was made and the discount was applied at 100%. Cause: Manual error entering the patient discount in the electronic medical record system. Effect: Individual received a larger discount than should have been provided according to policy. In addition, without sufficient internal control and review processes in place, there is a greater risk of additional errors occurring. Recommendation: We recommend the Organization investigate the underlying cause of the error, and provide education or incorporate some sort of reconciliation or review process to ensure sliding fee adjustments applied match the original determination. View of responsible officials: No disagreement with the finding. Management will provide training to individuals involved with entering sliding fee discounts into EMR and will investigate other review or reconciliation procedures that could be incorporated to reduce risk.

2024 – 001 Federal Agency: U.S Department of Health and Human Services Federal Program Title: Consolidated Health Centers Assistance Listing Numbers: 93.224/93.527 Award Period: 3/1/23 – 2/28/24 and 3/1/24 – 2/28/25 Type of Finding: • Significant Deficiency in Internal Control over Compliance Criteria or Specific Requirement: Per Title 42 Chapter 1 Subchapter D Section 51c303(f), “Health centers must have a schedule of fees or payments for the provision of their health services consistent with locally prevailing rates or charges designed to cover their reasonable costs of operation. They are also required to have a corresponding schedule of discounts applied and adjusted on the basis of the patient’s ability to pay.” Condition: During our testing of sliding fee discounts for health center patients qualifying for reduced charge visits, we identified one encounter where the sliding fee discount was calculated properly on the sliding fee application, but applied incorrectly to the patient account. Questioned costs: None. Context: The patient intake process occurred according to policy and a 20% adjustment was determined based on family size and income level. When the discount was applied to the patient's accounts, a manual error was made and the discount was applied at 100%. Cause: Manual error entering the patient discount in the electronic medical record system. Effect: Individual received a larger discount than should have been provided according to policy. In addition, without sufficient internal control and review processes in place, there is a greater risk of additional errors occurring. Recommendation: We recommend the Organization investigate the underlying cause of the error, and provide education or incorporate some sort of reconciliation or review process to ensure sliding fee adjustments applied match the original determination. View of responsible officials: No disagreement with the finding. Management will provide training to individuals involved with entering sliding fee discounts into EMR and will investigate other review or reconciliation procedures that could be incorporated to reduce risk.

2024 – 001 Federal Agency: U.S Department of Health and Human Services Federal Program Title: Consolidated Health Centers Assistance Listing Numbers: 93.224/93.527 Award Period: 3/1/23 – 2/28/24 and 3/1/24 – 2/28/25 Type of Finding: • Significant Deficiency in Internal Control over Compliance Criteria or Specific Requirement: Per Title 42 Chapter 1 Subchapter D Section 51c303(f), “Health centers must have a schedule of fees or payments for the provision of their health services consistent with locally prevailing rates or charges designed to cover their reasonable costs of operation. They are also required to have a corresponding schedule of discounts applied and adjusted on the basis of the patient’s ability to pay.” Condition: During our testing of sliding fee discounts for health center patients qualifying for reduced charge visits, we identified one encounter where the sliding fee discount was calculated properly on the sliding fee application, but applied incorrectly to the patient account. Questioned costs: None. Context: The patient intake process occurred according to policy and a 20% adjustment was determined based on family size and income level. When the discount was applied to the patient's accounts, a manual error was made and the discount was applied at 100%. Cause: Manual error entering the patient discount in the electronic medical record system. Effect: Individual received a larger discount than should have been provided according to policy. In addition, without sufficient internal control and review processes in place, there is a greater risk of additional errors occurring. Recommendation: We recommend the Organization investigate the underlying cause of the error, and provide education or incorporate some sort of reconciliation or review process to ensure sliding fee adjustments applied match the original determination. View of responsible officials: No disagreement with the finding. Management will provide training to individuals involved with entering sliding fee discounts into EMR and will investigate other review or reconciliation procedures that could be incorporated to reduce risk.