Audit 38162

2022-001 Program Income ? Sliding Fee Scale Health Center Program Cluster # 93.224 U.S. Department of Health and Human Services Contract H80CS00094 Condition ? Out of 60 encounters tested we noted the following: 1. Five (5) instances where there was no registration form in patient file. 2. Nineteen (19) instances where the sliding fee scale discount was not properly applied. Criteria ? Health centers are required to have a corresponding schedule of discounts applied and adjusted based on the patient?s ability to pay (42 USC 254b(k)(3)(G)(i). The patient?s ability to pay is based on the official poverty guideline, as revised annual by HHS (42 CFR sections 51c.107(b)(5), 56.108(b)(5), and 56.303(f). Cause ? Failure to obtain the required documentation was due to failure of the Corporation to properly monitor the process. Errors in calculating and/or applying the sliding fee discounts were primarily due to staff not properly following the process of entering and substantiating income within the NextGen software and the Corporation not properly monitoring the process. Conditions No. 1, and No. 2 are repeat finding from the prior year. See Summary Schedule of Prior Audit Findings 2021-001. Effect ? The Corporation could be incorrectly billing for services and maintaining customer account balances at incorrect amounts. Recommendation ? Staff should make every effort to obtain documentation of patient income, identification, and registration in accordance with internal policies and procedures. Patients should be billed full billing rates for all services until all documentation is received. We recommend additional staff training focusing on software familiarization and additional monitoring of the process by the Corporation. Management?s Response ? Management agrees with the finding. The Corporation is increasing its efforts to ensure that its policies and procedures surrounding documentation of patient income, identification, and registration is followed, and specifically that this documentation is archived correctly within every patient file. The Corporation has conducted several staff trainings and has revised its review procedures for checking compliance to improve monitoring of the process by the Corporation.

2022-002 Reporting ? Federal Financial Report Health Center Program Cluster # 93.918 U.S. Department of Health and Human Services Contract P06HA43531-01-01 Condition ? Annual Federal Financial Report for the reporting period 8/31/2022 was not filed timely. Criteria ? As specified in 2 CFR section 200.303 the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Adequate controls must be in place to ensure proper expenditures are reported in the applicable reporting periods. Cause ? Adequate controls were not in place to review and ensure report was filed timely Effect ? Reporting was not timely filed. However, in our review of report submissions all others were filed timely. Reporting was due on 1/30/23 and was submitted on 2/2/23. Recommendation ? Management should make every effort to ensure annual reports are submitted timely. The use of a schedule of submissions due that is reviewed by the appropriate personnel to provide a check that submissions are being timely filed. Management?s Response ? Management agrees with the finding. The Corporation is increasing its efforts to ensure that its policies and procedures are in place to ensure the timely submission of reports.

2022-001 Program Income ? Sliding Fee Scale Health Center Program Cluster # 93.224 U.S. Department of Health and Human Services Contract H80CS00094 Condition ? Out of 60 encounters tested we noted the following: 1. Five (5) instances where there was no registration form in patient file. 2. Nineteen (19) instances where the sliding fee scale discount was not properly applied. Criteria ? Health centers are required to have a corresponding schedule of discounts applied and adjusted based on the patient?s ability to pay (42 USC 254b(k)(3)(G)(i). The patient?s ability to pay is based on the official poverty guideline, as revised annual by HHS (42 CFR sections 51c.107(b)(5), 56.108(b)(5), and 56.303(f). Cause ? Failure to obtain the required documentation was due to failure of the Corporation to properly monitor the process. Errors in calculating and/or applying the sliding fee discounts were primarily due to staff not properly following the process of entering and substantiating income within the NextGen software and the Corporation not properly monitoring the process. Conditions No. 1, and No. 2 are repeat finding from the prior year. See Summary Schedule of Prior Audit Findings 2021-001. Effect ? The Corporation could be incorrectly billing for services and maintaining customer account balances at incorrect amounts. Recommendation ? Staff should make every effort to obtain documentation of patient income, identification, and registration in accordance with internal policies and procedures. Patients should be billed full billing rates for all services until all documentation is received. We recommend additional staff training focusing on software familiarization and additional monitoring of the process by the Corporation. Management?s Response ? Management agrees with the finding. The Corporation is increasing its efforts to ensure that its policies and procedures surrounding documentation of patient income, identification, and registration is followed, and specifically that this documentation is archived correctly within every patient file. The Corporation has conducted several staff trainings and has revised its review procedures for checking compliance to improve monitoring of the process by the Corporation.

2022-002 Reporting ? Federal Financial Report Health Center Program Cluster # 93.918 U.S. Department of Health and Human Services Contract P06HA43531-01-01 Condition ? Annual Federal Financial Report for the reporting period 8/31/2022 was not filed timely. Criteria ? As specified in 2 CFR section 200.303 the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Adequate controls must be in place to ensure proper expenditures are reported in the applicable reporting periods. Cause ? Adequate controls were not in place to review and ensure report was filed timely Effect ? Reporting was not timely filed. However, in our review of report submissions all others were filed timely. Reporting was due on 1/30/23 and was submitted on 2/2/23. Recommendation ? Management should make every effort to ensure annual reports are submitted timely. The use of a schedule of submissions due that is reviewed by the appropriate personnel to provide a check that submissions are being timely filed. Management?s Response ? Management agrees with the finding. The Corporation is increasing its efforts to ensure that its policies and procedures are in place to ensure the timely submission of reports.