Audit 377361

Health Center Program Cluster – Assistance Listing Numbers 93.224 and 93.527 U.S. Department of Health and Human Services Award No. 5 H80CS04226-18-00 Program Year 2023 Criteria or Specific Requirement – Special Tests and Provisions: Sliding Fee Discounts – 42 CFR 245(k)(3)(g); 42 CFR section 51c.303(g) and 42 CFR section 56.303(f). Condition – Patients who were eligible for sliding fee discounts under the Organization’s policy were not given sliding fee discounts or received sliding fee discounts inconsistent with the policy. Cause – The Organization did not comply with their sliding fee discount policy. Effect or potential effect – Improper sliding fee discounts were given and appropriate documentation was not maintained for all sliding fee discounts given. Questioned costs – None Context – A sample of 40 patients were tested out of the total population of 50,510 encounters. The sampling methodology used was not, and was not intended to be, statistically valid. Of the 40 transactions tested, 4 were determined to include errors in the application of the sliding fee discount program and policy. Identification as a repeat finding – Repeat finding of finding 2022-003 Recommendation – The Organization should continue to ensure all personnel understand the sliding fee scale policy and adhere to the requirements and guidelines set forth in the policy. Procedures should be implemented to ensure that eligible patients receive discounts in accordance with the sliding fee scale. Patient files should include documentation of eligibility to receive sliding fee scale discounts.

Certified Community Behavioral Health Clinic Expansion Grants Assistance Listing Number 93.696 U.S. Department of Health and Human Services Criteria or Specific Requirement – Cash Management (45 CFR 75.305) Condition – The Organization’s internal controls over compliance were not able to prevent an advance drawdown. Cause – The Organization was struggling to maintain adequate cash reserves and therefore advance drew on the award, with the knowledge that allowable expenditures would be incurred and covered by the draw in future periods. Effect or potential effect – Grant funds were drawn down sooner than administratively necessary. The one draw was not earned as of the end of three days prior to disbursement of allowable expenditures. Questioned Costs – None Context – Out of a population of sixteen draws, a sample of four draws were selected for testing. The sampling methodology used was not, and was not intended to be, statistically valid. Of the four draws tested, one draw was considered advanced Identification as a repeat finding, if applicable – Not a repeat finding Recommendation – The Organization should ensure procedures are followed to prevent cash draws from being drawn sooner than three days prior to disbursement of allowable expenditures.