Audit 387440

Health Center Program Assistance Listing Numbers 93.224 and 93.527 U.S. Department of Health and Human Services Award No. 6 H80CS00188-22-07 Program Year 2023 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 – Patients received a sliding fee discount that was inconsistent with the stated sliding fee discount categories under the Organization’s policy. Cause – The Organization did not comply with their sliding fee policy. Effect or potential effect – Sliding fee discounts were given to patients that were inconsistent with the Organization’s sliding fee discount policy. Questioned Cost – None Context - A sample of 25 encounters out of the total population of 389,021 encounters. The sampling methodology used is not and is not intended to be statistically valid. Four patients received a sliding fee adjustment that was inconsistent with the approved policy based on their income documentation Identification as a repeat finding – Not a repeat finding Recommendation – We recommend management 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 and the Health Center Program Compliance Manual.

Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution Assistance Listing Number 93.498 U.S. Department of Health and Human Services Criteria or specific requirement – Reporting (45 CFR 75.342) and Activities Allowed/ Unallowed and Allowable Costs/Cost Principles (Pub. L. No. 116-136, 134 Stat. 563 and Pub. L. No. 116-139, 134 Stat. 622, Pub. L. No. 116-260, Pub. L. No. 117-2) Condition – The Organization is required to prepare and submit period five Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution reporting. This report is to be prepared using accurate financial information and submitted by the deadline established. Cause - Management prepared the Period 5 Provider Relief Fund report using budgets approved for fiscal years 2021 through 2023 to calculate and support reported lost revenues. These budgets were approved after the onset of the COVID-19 public health emergency. Provider Relief Fund Reporting Guidance requires lost revenues to be supported using pre-pandemic budgets approved prior to the public health emergency or other allowable methodologies. Accordingly, the lost revenues reported for the 2021 through 2023 periods were inaccurate because the methodology selected by the Organization was not compliant with PRF reporting requirements. An allowable methodology would have included a comparison of the 2020 pre-pandemic budget to 2020 actual results, along with a comparison of 2019 actual revenues to actual revenues for 2021 through the second quarter of 2023. Effect or potential effect - Lost revenues reported in the Period 5 Provider Relief Fund report were not calculated in accordance with Provider Relief Fund reporting guidance. As a result, lost revenues for the 2021 through 2023 periods were inaccurately reported and may not be allowable for purposes of supporting the use of Provider Relief Fund expenditures. Questioned Cost – Unknown Context - The Organization prepared the Period 5 Provider Relief Fund report using post-pandemic budgets to calculate and support reported lost revenues, rather than using a compliant pre-pandemic budget or other allowable methodology in accordance with Provider Relief Fund reporting guidance. Identification as a repeat finding – Not a repeat finding Recommendation - Management should strengthen controls over the preparation and review of Provider Relief Fund reports to ensure lost revenues are calculated and reported in accordance with Provider Relief Fund reporting guidance.