Audit 395842

Special Provisions Federal Agency: U.S. Department of Health and Human Services Federal Program Title: Health Center Program Cluster Assistance Listing Numbers: 93.224 and 93.527 Federal Award Identification Number and Year: H80CS00109-24; H80CS00109-25 Award Period: May 1, 2024 – April 30, 2025; May 1, 2025 – April 30, 2026 Criteria or specific requirement: Health centers must prepare and apply a sliding fee discount schedule so that the amounts owed for health center services by eligible patients are adjusted (discounted) based on the patient’s ability to pay (42 USC 254(k)(3)(G); 42 CFR sections 51c.303(f), and (g); and 42 CFR sections 56.303(f), and (g)). Condition: The Organization did not maintain documentation to show that patients had been evaluated for eligibility under its sliding fee scale policy and did not apply sliding fee adjustments consistent with the sliding fee scale assigned. Questioned costs: None. Context:  Twelve (12) of sixty (60) encounters had the incorrect sliding fee discount applied based on the family size and income documentation provided.  For three (3) of sixty (60) encounters we could not verify if the family size and income were updated within a year of the patient visit date. Cause: This matter was initially identified during a prior audit and required the Organization to make an update to the electronic medical records software and process for obtaining the necessary sliding fee information. The Organization started its corrective action during the calendar year 2023 upon becoming aware of the matter. Although a prior corrective action plan has been implemented the matter has continued into the current year. Effect: Patients may not be assessed a correct sliding fee discount according to the Organization's sliding fee scale and their ability to pay. Repeat Finding: Yes, prior year finding 2024-002. Recommendation: Management should continue to provide training and education to front desk staff related to the process for collecting family size and income information, along with inputting it into the electronic medical records. We also recommend enhancing any current internal audits of patient visits to determine all required patient information has been obtained in accordance with TCA’s policies. Views of responsible officials: There is no disagreement with this finding.

Allowable Costs and Activities Federal Agency: U.S. Department of Health and Human Services Federal Program Title: Health Center Program Cluster Assistance Listing Numbers: 93.224 and 93.527 Federal Award Identification Number and Year: H80CS00109-24; H80CS00109-25 Award Period: May 1, 2024 – April 30, 2025; May 1, 2025 – April 30, 2026 Criteria or specific requirement: Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; and support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award (2 CFR 200.430(i)(1)). Condition: Payroll costs were allocated to grants in a manner inconsistent with the time and effort documentation provided. Questioned costs: none Context: One (1) of forty (40) allowable cost transactions selected for testing was related to payroll costs which were allocated to the grant in a manner inconsistent with the time and effort documentation provided. Amount allocated used a percentage less than the corresponding percentage on the time and effort documentation provided. Cause: Unknown Effect: Grants may be allocated costs in a manner which is inconsistent with the actual level of effort associated with the underlying employee. Repeat Finding: Yes, prior year finding 2024-003. Recommendation: Management should reinforce the requirement to retain time and effort documentation for all employees that are allocated to multiple grants and implement a review process whereby the allocation percentages used are compared to the employee attestations provided. Views of responsible officials: There is no disagreement with this finding.