Audit 387699

Health Center Program Cluster Assistance Listing 93.224 and 93.527 U.S. Department of Health and Human Services Award No. 2 H80CS26560-11-00 Program Year 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: Patients received a sliding fee discount that was inconsistent with the documented sliding fee discount categories under the Organization's Policy. In addition, the Organization did not update the sliding fee scale for annual changes to the poverty guidelines timely. Cause: The Organization did not comply with its sliding fee policy. Effect or Potenital Effect: Incorrect sliding fee discounts were given. Questioned Costs: None Context: A sample of 40 patients was tested out of the total population of 1,420 encounters and 12 errors were noted where patients received an incorrect sliding fee adjustment. The sampling methodology used is not and is not intended to be statistically valid. Identification as a Repeat Finding: Repeat Finding of 2023-003 Recommendation: We recommend that management continue to ensure that 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. In addition, management should ensure the Organization's sliding fee scale is updated annually in accordance with federal guidelines.

Health Center Program Cluster Assistance Listing 93.224 and 93.527 U.S. Department of Health and Human Services Award No. 2 H80CS26560-11-00 Program Year 2024 Criteria or Specific Requirement: Reporting (45 CFR 75.342) Condition: The Organization’s Uniform Data System (UDS) report did not agree to the underlying support. Cause: The Organization does not properly review the information used in preparing and submitting the UDS report. Effect or potential effect: Information provided is incorrect and does not provide accurate counts of patients or federal funds received. Questioned Costs: None Context: Errors and/or inadequate supporting documentation were identified for 9 our of 49 report attributes tested for the Organization's UDS report. Identification as a Repeat Finding: Not a repeat finding. Recommendation: The Organization should develop internal processes for preparing information that will be reported in the UDS report. In addition to this the Organization should develop a formal review process where a reviewer reviews and matches the amount to be reported with the documents used by the preparer.

COVID-19 Coronavirus State and Local Fiscal Recovery Funds Assistance Listing 21.027 U.S. Department of Treasury Missouri Coalition of Community Health Centers d/b/a Missouri Behavioral Health Council Criteria or Specific Requirement: Procurement, Suspension and Debarment – 45 CFR 75.329, 2 CFR 180 Condition: The Organization does not have adequate policies governing suspension and debarment requirements for the purchase of goods or services charged to federal awards. Specifically, the Organization did not verify that vendors were not suspended, debarred, or otherwise excluded. Cause: The Organization does not include a review of the federal suspended and debarment party list as part of the Organization's procurement policy. Effect or potential effect: Purchases were made that did not adhere to the federal government's suspension and debarment compliance requirements. Questioned Costs: None Context: 100% of eligible contracts were tested totaling $240,000. The Organization did not ensure the vendor was not suspended, debarred, or otherwise excluded before entering into contracts. The vendors were not on the suspended and debarred listing. Identification as a Repeat Finding: Repeat Finding of 2023-004 Recommendation: The Organization should develop a suspension and debarment policy and ensure proper staff education on the policy once established. In addition, the Organization should review the policy on an annual basis to ensure it is consistent with the Uniform Guidance.