Audit 401709

2024-004—Late Audit Report Federal program information: Funding agency: U.S. Department of Health and Human Services Title: All Assistance Listing Number (ALN): All Award number and year: All Criteria: According to 2 CFR Part 200.512, the annual single audit must be completed and the data collection form and reporting package must be submitted within the earlier of 30 calendar days after receipt of the auditor's report or nine months after the end of the audit period (September 30, 2024). Condition: FCCH’s 2024 single audit reporting package was not submitted by the due date of September 30, 2025. Questioned Costs: None Context: N/A Cause: FCCH experienced turnover in the accounting department in key positions in recent years, which caused significant delays in completion of the year-end reconciliations of the financial statements and the schedule of expenditures of federal awards. Effect: FCCH was unable to completely reconcile certain general ledger accounts timely, which resulted in the audit not being completed within the reporting deadline. Auditor’s Recommendations: FCCH should implement its approved policies and procedures and complete the year-end account reconciliations in a timely manner to ensure the timely completion of the audit and submission of the single audit reporting package. Management’s Response: FCCH leadership inherited a situation in which the organization was woefully behind in its accounting records. The existing team has relentlessly pursued getting caught up. Turnover has hampered our efforts, yet we remain committed to the task. We are committed to continuing the effort to become fully compliant and to submit our 2025 audit on time. The FCCH Board of Directors shall ensure accountability for completing all audits in the future on time.

2024-005—Special Tests and Provisions—Sliding Fee Discount Program Federal program information: Funding agency: U.S. Department of Health and Human Services Title: Health Center Cluster Assistance Listing Number (ALN): 93.224 Award number and year: H80CS00202 (1/1/2024 – 12/31/2024) Criteria: According to 42 CFR Part 51c.303(f) and FCCH’s Sliding Fee Discount and Related Billing and Collections Program Policies and Procedures, a community health center must have prepared a schedule of fees or payments for the provision of its services designed to cover its reasonable costs of operation and a corresponding schedule of discounts adjusted on the basis of the patient's ability to pay, provided that such schedule of discounts shall provide for a full discount to individuals and families with annual incomes at or below those set forth in the poverty guidelines updated periodically in the Federal Register by the U.S. Department of Health and Human Services under the authority of 42 U.S.C. 9902(2); and for no discount to individuals and families with annual incomes greater than twice those set forth in such guidelines. Condition: For one of 30 medical claims tested, the amount billed did not agree to FCCH’s fee schedule for the procedures performed after applying FCCH’s sliding fee discount from the Sliding Fee Discount Program (SFDP). Questioned Costs: None Context: One of 30 medical claims tested. Cause: At the patient’s initial visit, they did not bring in income documentation to qualify for a sliding fee discount. However, the patient did bring in the income documentation within 30 days of the date of service, but the billing department was not notified of this information so that the sliding fee discount could be applied. Effect: FCCH is not in compliance with 42 CFR Part 51c.303(f). Additionally, FCCH is not in compliance with its Sliding Fee Discount and Related Billing and Collections Program Policies and Procedures. Auditor’s Recommendations: FCCH should implement its established policies and procedures which require adherence to the approved schedule of fees for services and discounts. FCCH should also consider performing its own review of medical claims billed to determine the prevalence of these errors. Management’s Response: Management acknowledges the finding. FCCH agrees that the claim in question did not reflect the appropriate sliding fee discount because the billing department was not notified that the patient submitted income documentation within the 30-day eligibility window. FCCH recognizes the importance of ensuring that all departments consistently follow established Sliding Fee Discount Program (SFDP) procedures. To address this issue, FCCH has implemented the following corrective actions: • Reinforce communication protocols between front desk/eligibility staff and the billing department to ensure that any income documentation received after the date of service is promptly communicated and documented. • Provide refresher training to front desk, eligibility, and billing staff on SFDP requirements, including the 30-day documentation rule and the process for updating patient classifications. • Initiated an internal review of a sample of medical claims to assess whether similar errors occurred and to confirm that corrective measures are effective. FCCH remains committed to full compliance with 42 CFR Part 51c.303(f) and its internal Sliding Fee Discount and Related Billing and Collections Program Policies and Procedures. Management will continue monitoring to ensure ongoing adherence and prevent recurrence.