Audit 405593

2025-001 Sliding Scale Determination Special Tests and Provisions ALN 93.224 Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) US Department of Health and Human Services Contract Numbers H80CS30749-08, H80CS30749-09, and H8NCS54017-01-02 Contract Periods April 1, 2024 – March 31, 2025 and April 1, 2025 – March 31, 2026 and September 1, 2024 – August 31, 2025 Conditions and Criteria: The requirements under 42 CFR 51c.303(f) provide requirements to 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, except that nominal fees for services may be collected from individuals with annual incomes at or below such levels where imposition of such fees is consistent with project goals. In the 2025 audit, for 2 of 40 samples selected for testing, OCHS calculated the sliding scale level incorrectly based on income and family size documentation. Effect: The effect is that two patient’s sliding scale levels were calculated incorrectly and their fees were incorrectly applied. Cause: Determining a patient’s sliding fee discount level is to be performed on an annual basis. During the 2025 fiscal year, OCHS had employee turnover in the compliance department. Although OCHS has policies in place for calculating patient sliding scale level determination based on income and family size, the calculations were performed incorrectly due to a lack of monitoring in place to ensure the requirement under 42 CFR 51c.303(f) was adhered to. Auditor Recommendation: We recommend that a procedure should be put in place to monitor whether the calculation in sliding scale levels are correctly calculated and applied per patient documentation. Planned Corrective Action: See the following Corrective Action Plan section for management’s planned corrective action.

2025-002 Cash Management ALN 93.224 Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) US Department of Health and Human Services Contract Numbers H80CS30749-06, H80CS30749-07, and H8NCS54017-01-02 Contract Periods September 1, 2024 – August 31, 2025 and April 1, 2024 – March 31, 2025 Conditions and Criteria: The requirement under 2 CFR 200.305 provides requirements for the timely disbursement of funds after receipt of federal grant funds. For recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means. See § 200.302(b)(6). Except as noted in this part, the Federal agency must require recipients to use only OMBapproved, government-wide information collections to request payment. In the 2025 audit, for 4 of the 10 samples selected for testing, OCHS did not disburse federal funds within the required one business day after receipt. Effect: The effect is that federal funds were not disbursed within the OMB Compliance requirement of one business day after receipt of the federal funds. Cause: There were staffing changes in Grant Management and CFO positions. OCHS has policies in place to minimize time elapse between disbursement of federal funds after receipt, however there was a lack of monitoring to ensure timely disbursement of federal funds as required under 2 CFR 200.305. Auditor Recommendation: We recommend a procedure be added to ensure there is additional monitoring over federal grant cash timely remittance. Planned Corrective Action: See the following Corrective Action Plan section for management’s planned corrective action.

2025-003 (Repeat Finding) Retaining Sliding Scale Determination Documentation Special Tests and Provisions ALN 93.224 Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) US Department of Health and Human Services Contract Numbers H80CS30749-06 and H80CS30749-07 Contract Periods April 1, 2022 – March 31, 2023 and April 1, 2023 – March 31, 2024 Conditions and Criteria: The requirement under 45 CFR 75.361 provides requirements for the retention of records for grantees. In addition, 2 CFR 200.303 provides requirements to establish and maintain effective internal controls over Federal awards. Specifically, it states that financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Health and Human Services awarding agency of pass-through entity in the case of a subrecipient. In the 2023 audit, for 5 out of 40 samples selected for testing, it was noted that OCHS did not retain the proper documents that the patients had submitted that included their income and family size or the documents completed by OCHS showing the sliding fee discount determination for these patients. Effect: The effect is that records that are required to be retained were not retained and evidence of how the sliding fee discount was determined could not be examined. Questioned Costs: Any likely questioned costs could not be determined since compliance testing was unable to be performed due to the lack of documentation. It should be noted that there were no exceptions for 35 samples that were able to be tested, and for 5 samples with insufficient documentation, 3 had partial documentation of income (i.e., pay stubs) and 2 had no documentation of income as it was not maintained. However, the sliding scale calculation was completed for all 40 samples. Cause: Determining the sliding fee discount level for each patient is reassessed on an annual basis. During the year, there was employee turnover in the compliance department. Although OCHS has a records retention policy, there was a lack of monitoring in place to ensure that the requirement under 45 CFR 75.361 was adhered to. Auditor Recommendation: A procedure should be put in place to monitor whether the record retention policy is followed. Current Status: During the current year, fiscal 2025 audit testing, no samples lacked support for the sliding fee scale determination. However, there is a three-year documentation retention requirement per 45 CFR 200.303. If asked to produce documentation for fiscal year 2023, OCHS would not be able to do so, therefore, the 2023 fiscal year finding was repeated. Planned Corrective Action: See the following Corrective Action Plan section for management’s planned corrective action.