Finding #: 2022-002 Cash Management – Noncompliance (not material to compliance requirement)
Identification of Federal Program and Award
Program title: U.S. Department of Health and Human Services (DHHS): Public Health Services Act, Title III, Section 330 (Health Center Cluster)
CFDA #: 93.224/93.527 Award #: C8E44790 Program Year: 2022
Criteria
Pursuant to 2 CFR section 200.305(b), Non-Federal entities must minimize the time elapsing between the transfer of funds from the U.S. Treasury or pass-through entity and disbursement by the non-Federal entity for direct program or project costs and the proportionate share of allowable indirect costs. Under the advance payment method, a non-Federal entity must be paid in advance provided that it maintains, or demonstrates the willingness to maintain, both written procedures that minimize the time elapsing between the transfer of funds from the U.S. Treasury and disbursement by the non-Federal entity, as well as a financial management system that meets the specified standards for fund control and accountability.
Condition
During our testing of cash management, we noted an instance of noncompliance relating to the health center’s effort to minimize the time between drawing and disbursing federal funds. 1 out of 6 drawdowns was identified as a portion of unearned revenue. Upon further inspection, auditor identified a total of $74,580 in deferred revenue that was not disbursed timely (time elapsed between the transfer of funds and disbursement exceeded the three-day rule).
Cause
Health center personnel were not following cash management policies and procedures (“DHHS Draw Down Procedure #2.530”) that comply with 2 CFR section 200.305(b).
Effect
Possibility of interest payments due, and of draw down restriction being placed on Payment Management System (PMS) account or denial of future funding.
Questioned Costs
$74,580
Perspective Information
We tested a statistically valid sample of 6 out of 17 total cash drawdowns and determined that the audit finding represented an isolated instance.
Repeat Finding
This finding is not a repeated finding.
Recommendation
We recommend that management review DHHS draw down policies and procedures in place to ensure CAMcare is in compliance with the compliance requirements of 2 CFR section 200.305(b).
Views of Responsible Officials
Management recognizes the noncompliance; on November 29, 2023, CAMcare’s CEO, Jillian Hudspeth, and CFO, Christopher Bernardi, agreed with this finding, and explained that CAMcare’s original budget for the C8E grant was to expand operations at the Clementon location. However, after the initial site plans and architectural
drawings were completed and paid for, the costs of materials and labor had increased significantly due to supply chain issues. Management made the decision to cancel the project and pivot to different areas of need. Because the project was cancelled, HRSA disallowed the site plan and architecture costs. CAMcare’s CFO and grant manager at the time were given verbal approval to reduce a future drawdown by the amount that had been disallowed.
Finding #: 2022-003 Period of Performance – Noncompliance (not material to compliance requirement)
Identification of Federal Program and Award
Program title: U.S. Department of Health and Human Services (DHHS): Public Health Services Act, Title III, Section 330 (Health Center Cluster)
CFDA #: 93.224/93.527 Award #: H8DCS36483 Program Year: 2022
Criteria
Pursuant to 2 CFR sections 200.308, 200.309, and 200.403(h), a non-Federal entity may charge to the Federal award only allowable costs incurred during the approved budget period of a federal award's period of performance and any costs incurred before the Federal awarding agency or pass-through entity made the Federal award that were authorized by the Federal awarding agency or pass-through entity. Pursuant to 2 CFR section 200.305(b)(5), to the extent available, the non-Federal entity must disburse funds available from program income and interest earned on such funds before requesting additional cash payments.
Condition
During our testing of period of performance, we noted instances of noncompliance relating to the health center’s recognition of expenditures beyond the award’s period of performance. After inspection of invoices and canceled checks supporting disbursements tested, the auditor identified 3 out of 40 expenditures where costs were incurred after the period of performance end date. Upon further investigation, the auditor determined that $153,005 of the $433,455 amount reported as 2022 federal expenditures under award H8DCS36483 was incurred beyond the period of performance end date.
Cause
Health center personnel were not following financial expense allocation of revenue policies and procedures, which state that federal funds will be utilized according to regulations and what is established on the budget information form submitted with the grant application.
Effect
Possibility of interest payments due, and of draw down restriction being placed on Payment Management System (PMS) account or denial of future funding.
Questioned Costs
$153,005
Perspective Information
We tested a statistically valid sample of 40 out of 250+ federal expenditures and determined that the audit finding represented a systemic problem.
Repeat Finding
This finding is not a repeated finding.
Recommendation
We recommend that management review financial expense allocation of revenue policies and closely monitor grant procedures in place to ensure CAMcare is in compliance with budget information stipulated in grant agreements.
Views of Responsible Officials
Management recognizes the noncompliance; on November 29, 2023, CAMcare’s CEO, Jillian Hudspeth, and CFO, Christopher Bernardi, agreed with this finding, and explained that the issue occurred during a time period when none of the current authorizing officials were employed by CAMcare.
Finding #: 2022-004 Reporting – Noncompliance (not material to compliance requirement)
Identification of Federal Program and Award
Program title: U.S. Department of Health and Human Services (DHHS): Public Health Services Act, Title III, Section 330 (Health Center Cluster)
CFDA #: 93.224/93.527 Award #: H8FCS40520 Program Year: 2022
Criteria
Pursuant to 2 CFR 200.302, the financial management system of each non-Federal entity must provide for accurate, current, and complete disclosure of the financial results of each Federal award, and records that identify adequately the source and application of funds for federally-funded activities and supported by source documentation.
Condition
During our testing of financial reporting, we noted an instance of noncompliance relating to the health center’s accurate reporting of FFRs. 1 out of 4 FFRs had no expenditures reported on line 10e, and the amount of federal share of expenditures reported did not reconcile to the accounting records.
Cause
CAMcare’s documented policies and procedures include one control procedure regarding annual FFR completion, which states, “Annually the FFR report is done in EHB reconciling to the quarterly reports submitted in the PMS system.” Accordingly, the control procedure lacks description of written roles and responsibilities to ensure personnel responsible for review and for completion of FFR reports are identified, and to ensure duties are defined for reconciling the FFR amounts to the accounting records prior to submission.
Effect
Possibility of draw down restriction being placed on Payment Management System (PMS) account or denial of future funding.
Questioned Costs
None
Perspective Information
We tested the entire population of 4 total Federal Financial Reports and determined that the audit finding represented an isolated incident.
Repeat Finding
This finding is not a repeated finding.
Recommendation
We recommend that management review DHHS draw down and FFR policies and procedures in place and revise such procedures to describe roles and responsibilities to mitigate the risk of inaccurate reporting and to ensure CAMcare is in compliance with the compliance requirements of 2 CFR 200 section 302.
Views of Responsible Officials
Management recognizes the noncompliance; on November 29, 2023, CAMcare’s CEO, Jillian Hudspeth, and CFO, Christopher Bernardi, agreed with this finding, and explained that when the FFR was submitted by the prior CFO, it was correct at the time. However, due to miscommunications between the people purchasing items covered by the grants and CAMcare’s accounting department, it wasn’t discovered until later that CAMcare had missed expenses during the period covered by the FFR. Those expenses were then reported on a future FFR. CAMcare has since implemented a system whereby every purchase needs to identify the funding source before it gets to the accounting department to prevent this situation from occurring in the future.
Finding #: 2022-005 Special Tests and Provisions – Noncompliance (not material to compliance requirement)
Identification of Federal Program and Award
Program title: U.S. Department of Health and Human Services (DHHS): Public Health Services Act, Title III, Section 330 (Health Center Cluster)
CFDA #: 93.224/93.527 Award #: 17H80CS00172 Program Year: 2022
Criteria
Pursuant to 42 CFR section 56.303(g)(2), health centers must make every reasonable effort, including the establishment of systems for eligibility determination, billing, and collection, to secure from patients, payments for services in accordance with the schedule of fees and discounts.
Condition
During our testing of special tests and provisions, we noted instances of noncompliance relating to the health center’s application of sliding fee discounts to patient charges; 4 out of 40 patient records sampled showed instances where patient charges were not appropriately adjusted to be consistent with the sliding fee discount schedule. Compliance testing was not able to be completed for 1 out of 40 patient records, as the sliding fee discount was applied to a patient visit for which the financial screening application process was not completed (no records of salary or family size were provided to support the scale rating, which also was not provided).
Cause
Personnel were not following CAMcare’s Financial Sliding Fee Scale Policies and Procedures, which comply with 42 CFR section 56.303(g)(2).
Effect
Possibility of draw down restriction being placed on Payment Management System (PMS) account or denial of future funding.
Questioned Costs
None
Perspective Information
We tested a statistically valid sample of 40 patient visits out of a total population of 250+ uncompensated care program visits and determined that the audit finding represented a systemic problem.
Repeat Finding
This finding is not a repeated finding.
Recommendation
We recommend that management review financial sliding fee scale policies and procedures in place and closely monitor the patient billing process to ensure CAMcare is in compliance with the compliance requirements of 42 CFR section 56.303(g)(2).
Views of Responsible Officials
Management recognizes the noncompliance; on November 29, 2023, CAMcare’s CEO, Jillian Hudspeth, and CFO, Christopher Bernardi, agreed with this finding, and explained that Management plans to offer additional training to the Financial Screening Department members and require the department manager to perform a periodic audit of applications.
Finding #: 2022-005 Special Tests and Provisions – Noncompliance (not material to compliance requirement)
Identification of Federal Program and Award
Program title: U.S. Department of Health and Human Services (DHHS): Public Health Services Act, Title III, Section 330 (Health Center Cluster)
CFDA #: 93.224/93.527 Award #: 17H80CS00172 Program Year: 2022
Criteria
Pursuant to 42 CFR section 56.303(g)(2), health centers must make every reasonable effort, including the establishment of systems for eligibility determination, billing, and collection, to secure from patients, payments for services in accordance with the schedule of fees and discounts.
Condition
During our testing of special tests and provisions, we noted instances of noncompliance relating to the health center’s application of sliding fee discounts to patient charges; 4 out of 40 patient records sampled showed instances where patient charges were not appropriately adjusted to be consistent with the sliding fee discount schedule. Compliance testing was not able to be completed for 1 out of 40 patient records, as the sliding fee discount was applied to a patient visit for which the financial screening application process was not completed (no records of salary or family size were provided to support the scale rating, which also was not provided).
Cause
Personnel were not following CAMcare’s Financial Sliding Fee Scale Policies and Procedures, which comply with 42 CFR section 56.303(g)(2).
Effect
Possibility of draw down restriction being placed on Payment Management System (PMS) account or denial of future funding.
Questioned Costs
None
Perspective Information
We tested a statistically valid sample of 40 patient visits out of a total population of 250+ uncompensated care program visits and determined that the audit finding represented a systemic problem.
Repeat Finding
This finding is not a repeated finding.
Recommendation
We recommend that management review financial sliding fee scale policies and procedures in place and closely monitor the patient billing process to ensure CAMcare is in compliance with the compliance requirements of 42 CFR section 56.303(g)(2).
Views of Responsible Officials
Management recognizes the noncompliance; on November 29, 2023, CAMcare’s CEO, Jillian Hudspeth, and CFO, Christopher Bernardi, agreed with this finding, and explained that Management plans to offer additional training to the Financial Screening Department members and require the department manager to perform a periodic audit of applications.
Finding #: 2022-006 Special Tests and Provisions, Controls over Compliance – Significant Deficiency
Identification of Federal Program and Award
Program title: U.S. Department of Health and Human Services (DHHS): Public Health Services Act, Title III, Section 330 (Health Center Cluster)
CFDA #: 93.224/93.527 Award #: 17H80CS00172 Program Year: 2022
Criteria
CAMcare’s internal controls over the special tests and provisions compliance area include the financial screening processes and related control activities to complete patient applications during financial screening, including reviewing and approving patient applications and calculating of scale ratings per patient based on annual income and family size.
Condition
During our testing of special tests and provisions, we noted control deficiencies related to the financial screening process; 5 out of 40 patient records sampled showed instances where the patient scale ratings were calculated incorrectly on the patient applications, and for 1 out of 40 samples, the sliding fee discount was applied to a patient visit for which the financial screening application process was not completed.
Cause
Financial screening personnel were not applying control procedures correctly in accordance with their financial screening process.
Effect
Possibility of inaccurate discounts given to patients and significant or material noncompliance with major federal programs.
Questioned Costs
None
Perspective Information
We tested a statistically valid sample of 40 patient visits out of a total population of 250+ uncompensated care program visits and determined that the audit finding represented a systemic problem.
Repeat Finding
This finding is not a repeated finding.
Recommendation
We recommend that management review the financial screening process in place and closely monitor the patient application process to emphasize the importance of correct implementation of control procedures.
Views of Responsible Officials
Management recognizes the deficiency; on November 29, 2023, CAMcare’s CEO, Jillian Hudspeth, and CFO, Christopher Bernardi, agreed with this finding, and explained that Management plans to offer additional training to the Financial Screening Department members and require the department manager to perform a periodic audit of applications.
Finding #: 2022-006 Special Tests and Provisions, Controls over Compliance – Significant Deficiency
Identification of Federal Program and Award
Program title: U.S. Department of Health and Human Services (DHHS): Public Health Services Act, Title III, Section 330 (Health Center Cluster)
CFDA #: 93.224/93.527 Award #: 17H80CS00172 Program Year: 2022
Criteria
CAMcare’s internal controls over the special tests and provisions compliance area include the financial screening processes and related control activities to complete patient applications during financial screening, including reviewing and approving patient applications and calculating of scale ratings per patient based on annual income and family size.
Condition
During our testing of special tests and provisions, we noted control deficiencies related to the financial screening process; 5 out of 40 patient records sampled showed instances where the patient scale ratings were calculated incorrectly on the patient applications, and for 1 out of 40 samples, the sliding fee discount was applied to a patient visit for which the financial screening application process was not completed.
Cause
Financial screening personnel were not applying control procedures correctly in accordance with their financial screening process.
Effect
Possibility of inaccurate discounts given to patients and significant or material noncompliance with major federal programs.
Questioned Costs
None
Perspective Information
We tested a statistically valid sample of 40 patient visits out of a total population of 250+ uncompensated care program visits and determined that the audit finding represented a systemic problem.
Repeat Finding
This finding is not a repeated finding.
Recommendation
We recommend that management review the financial screening process in place and closely monitor the patient application process to emphasize the importance of correct implementation of control procedures.
Views of Responsible Officials
Management recognizes the deficiency; on November 29, 2023, CAMcare’s CEO, Jillian Hudspeth, and CFO, Christopher Bernardi, agreed with this finding, and explained that Management plans to offer additional training to the Financial Screening Department members and require the department manager to perform a periodic audit of applications.
Finding #: 2022-002 Cash Management – Noncompliance (not material to compliance requirement)
Identification of Federal Program and Award
Program title: U.S. Department of Health and Human Services (DHHS): Public Health Services Act, Title III, Section 330 (Health Center Cluster)
CFDA #: 93.224/93.527 Award #: C8E44790 Program Year: 2022
Criteria
Pursuant to 2 CFR section 200.305(b), Non-Federal entities must minimize the time elapsing between the transfer of funds from the U.S. Treasury or pass-through entity and disbursement by the non-Federal entity for direct program or project costs and the proportionate share of allowable indirect costs. Under the advance payment method, a non-Federal entity must be paid in advance provided that it maintains, or demonstrates the willingness to maintain, both written procedures that minimize the time elapsing between the transfer of funds from the U.S. Treasury and disbursement by the non-Federal entity, as well as a financial management system that meets the specified standards for fund control and accountability.
Condition
During our testing of cash management, we noted an instance of noncompliance relating to the health center’s effort to minimize the time between drawing and disbursing federal funds. 1 out of 6 drawdowns was identified as a portion of unearned revenue. Upon further inspection, auditor identified a total of $74,580 in deferred revenue that was not disbursed timely (time elapsed between the transfer of funds and disbursement exceeded the three-day rule).
Cause
Health center personnel were not following cash management policies and procedures (“DHHS Draw Down Procedure #2.530”) that comply with 2 CFR section 200.305(b).
Effect
Possibility of interest payments due, and of draw down restriction being placed on Payment Management System (PMS) account or denial of future funding.
Questioned Costs
$74,580
Perspective Information
We tested a statistically valid sample of 6 out of 17 total cash drawdowns and determined that the audit finding represented an isolated instance.
Repeat Finding
This finding is not a repeated finding.
Recommendation
We recommend that management review DHHS draw down policies and procedures in place to ensure CAMcare is in compliance with the compliance requirements of 2 CFR section 200.305(b).
Views of Responsible Officials
Management recognizes the noncompliance; on November 29, 2023, CAMcare’s CEO, Jillian Hudspeth, and CFO, Christopher Bernardi, agreed with this finding, and explained that CAMcare’s original budget for the C8E grant was to expand operations at the Clementon location. However, after the initial site plans and architectural
drawings were completed and paid for, the costs of materials and labor had increased significantly due to supply chain issues. Management made the decision to cancel the project and pivot to different areas of need. Because the project was cancelled, HRSA disallowed the site plan and architecture costs. CAMcare’s CFO and grant manager at the time were given verbal approval to reduce a future drawdown by the amount that had been disallowed.
Finding #: 2022-003 Period of Performance – Noncompliance (not material to compliance requirement)
Identification of Federal Program and Award
Program title: U.S. Department of Health and Human Services (DHHS): Public Health Services Act, Title III, Section 330 (Health Center Cluster)
CFDA #: 93.224/93.527 Award #: H8DCS36483 Program Year: 2022
Criteria
Pursuant to 2 CFR sections 200.308, 200.309, and 200.403(h), a non-Federal entity may charge to the Federal award only allowable costs incurred during the approved budget period of a federal award's period of performance and any costs incurred before the Federal awarding agency or pass-through entity made the Federal award that were authorized by the Federal awarding agency or pass-through entity. Pursuant to 2 CFR section 200.305(b)(5), to the extent available, the non-Federal entity must disburse funds available from program income and interest earned on such funds before requesting additional cash payments.
Condition
During our testing of period of performance, we noted instances of noncompliance relating to the health center’s recognition of expenditures beyond the award’s period of performance. After inspection of invoices and canceled checks supporting disbursements tested, the auditor identified 3 out of 40 expenditures where costs were incurred after the period of performance end date. Upon further investigation, the auditor determined that $153,005 of the $433,455 amount reported as 2022 federal expenditures under award H8DCS36483 was incurred beyond the period of performance end date.
Cause
Health center personnel were not following financial expense allocation of revenue policies and procedures, which state that federal funds will be utilized according to regulations and what is established on the budget information form submitted with the grant application.
Effect
Possibility of interest payments due, and of draw down restriction being placed on Payment Management System (PMS) account or denial of future funding.
Questioned Costs
$153,005
Perspective Information
We tested a statistically valid sample of 40 out of 250+ federal expenditures and determined that the audit finding represented a systemic problem.
Repeat Finding
This finding is not a repeated finding.
Recommendation
We recommend that management review financial expense allocation of revenue policies and closely monitor grant procedures in place to ensure CAMcare is in compliance with budget information stipulated in grant agreements.
Views of Responsible Officials
Management recognizes the noncompliance; on November 29, 2023, CAMcare’s CEO, Jillian Hudspeth, and CFO, Christopher Bernardi, agreed with this finding, and explained that the issue occurred during a time period when none of the current authorizing officials were employed by CAMcare.
Finding #: 2022-004 Reporting – Noncompliance (not material to compliance requirement)
Identification of Federal Program and Award
Program title: U.S. Department of Health and Human Services (DHHS): Public Health Services Act, Title III, Section 330 (Health Center Cluster)
CFDA #: 93.224/93.527 Award #: H8FCS40520 Program Year: 2022
Criteria
Pursuant to 2 CFR 200.302, the financial management system of each non-Federal entity must provide for accurate, current, and complete disclosure of the financial results of each Federal award, and records that identify adequately the source and application of funds for federally-funded activities and supported by source documentation.
Condition
During our testing of financial reporting, we noted an instance of noncompliance relating to the health center’s accurate reporting of FFRs. 1 out of 4 FFRs had no expenditures reported on line 10e, and the amount of federal share of expenditures reported did not reconcile to the accounting records.
Cause
CAMcare’s documented policies and procedures include one control procedure regarding annual FFR completion, which states, “Annually the FFR report is done in EHB reconciling to the quarterly reports submitted in the PMS system.” Accordingly, the control procedure lacks description of written roles and responsibilities to ensure personnel responsible for review and for completion of FFR reports are identified, and to ensure duties are defined for reconciling the FFR amounts to the accounting records prior to submission.
Effect
Possibility of draw down restriction being placed on Payment Management System (PMS) account or denial of future funding.
Questioned Costs
None
Perspective Information
We tested the entire population of 4 total Federal Financial Reports and determined that the audit finding represented an isolated incident.
Repeat Finding
This finding is not a repeated finding.
Recommendation
We recommend that management review DHHS draw down and FFR policies and procedures in place and revise such procedures to describe roles and responsibilities to mitigate the risk of inaccurate reporting and to ensure CAMcare is in compliance with the compliance requirements of 2 CFR 200 section 302.
Views of Responsible Officials
Management recognizes the noncompliance; on November 29, 2023, CAMcare’s CEO, Jillian Hudspeth, and CFO, Christopher Bernardi, agreed with this finding, and explained that when the FFR was submitted by the prior CFO, it was correct at the time. However, due to miscommunications between the people purchasing items covered by the grants and CAMcare’s accounting department, it wasn’t discovered until later that CAMcare had missed expenses during the period covered by the FFR. Those expenses were then reported on a future FFR. CAMcare has since implemented a system whereby every purchase needs to identify the funding source before it gets to the accounting department to prevent this situation from occurring in the future.
Finding #: 2022-005 Special Tests and Provisions – Noncompliance (not material to compliance requirement)
Identification of Federal Program and Award
Program title: U.S. Department of Health and Human Services (DHHS): Public Health Services Act, Title III, Section 330 (Health Center Cluster)
CFDA #: 93.224/93.527 Award #: 17H80CS00172 Program Year: 2022
Criteria
Pursuant to 42 CFR section 56.303(g)(2), health centers must make every reasonable effort, including the establishment of systems for eligibility determination, billing, and collection, to secure from patients, payments for services in accordance with the schedule of fees and discounts.
Condition
During our testing of special tests and provisions, we noted instances of noncompliance relating to the health center’s application of sliding fee discounts to patient charges; 4 out of 40 patient records sampled showed instances where patient charges were not appropriately adjusted to be consistent with the sliding fee discount schedule. Compliance testing was not able to be completed for 1 out of 40 patient records, as the sliding fee discount was applied to a patient visit for which the financial screening application process was not completed (no records of salary or family size were provided to support the scale rating, which also was not provided).
Cause
Personnel were not following CAMcare’s Financial Sliding Fee Scale Policies and Procedures, which comply with 42 CFR section 56.303(g)(2).
Effect
Possibility of draw down restriction being placed on Payment Management System (PMS) account or denial of future funding.
Questioned Costs
None
Perspective Information
We tested a statistically valid sample of 40 patient visits out of a total population of 250+ uncompensated care program visits and determined that the audit finding represented a systemic problem.
Repeat Finding
This finding is not a repeated finding.
Recommendation
We recommend that management review financial sliding fee scale policies and procedures in place and closely monitor the patient billing process to ensure CAMcare is in compliance with the compliance requirements of 42 CFR section 56.303(g)(2).
Views of Responsible Officials
Management recognizes the noncompliance; on November 29, 2023, CAMcare’s CEO, Jillian Hudspeth, and CFO, Christopher Bernardi, agreed with this finding, and explained that Management plans to offer additional training to the Financial Screening Department members and require the department manager to perform a periodic audit of applications.
Finding #: 2022-005 Special Tests and Provisions – Noncompliance (not material to compliance requirement)
Identification of Federal Program and Award
Program title: U.S. Department of Health and Human Services (DHHS): Public Health Services Act, Title III, Section 330 (Health Center Cluster)
CFDA #: 93.224/93.527 Award #: 17H80CS00172 Program Year: 2022
Criteria
Pursuant to 42 CFR section 56.303(g)(2), health centers must make every reasonable effort, including the establishment of systems for eligibility determination, billing, and collection, to secure from patients, payments for services in accordance with the schedule of fees and discounts.
Condition
During our testing of special tests and provisions, we noted instances of noncompliance relating to the health center’s application of sliding fee discounts to patient charges; 4 out of 40 patient records sampled showed instances where patient charges were not appropriately adjusted to be consistent with the sliding fee discount schedule. Compliance testing was not able to be completed for 1 out of 40 patient records, as the sliding fee discount was applied to a patient visit for which the financial screening application process was not completed (no records of salary or family size were provided to support the scale rating, which also was not provided).
Cause
Personnel were not following CAMcare’s Financial Sliding Fee Scale Policies and Procedures, which comply with 42 CFR section 56.303(g)(2).
Effect
Possibility of draw down restriction being placed on Payment Management System (PMS) account or denial of future funding.
Questioned Costs
None
Perspective Information
We tested a statistically valid sample of 40 patient visits out of a total population of 250+ uncompensated care program visits and determined that the audit finding represented a systemic problem.
Repeat Finding
This finding is not a repeated finding.
Recommendation
We recommend that management review financial sliding fee scale policies and procedures in place and closely monitor the patient billing process to ensure CAMcare is in compliance with the compliance requirements of 42 CFR section 56.303(g)(2).
Views of Responsible Officials
Management recognizes the noncompliance; on November 29, 2023, CAMcare’s CEO, Jillian Hudspeth, and CFO, Christopher Bernardi, agreed with this finding, and explained that Management plans to offer additional training to the Financial Screening Department members and require the department manager to perform a periodic audit of applications.
Finding #: 2022-006 Special Tests and Provisions, Controls over Compliance – Significant Deficiency
Identification of Federal Program and Award
Program title: U.S. Department of Health and Human Services (DHHS): Public Health Services Act, Title III, Section 330 (Health Center Cluster)
CFDA #: 93.224/93.527 Award #: 17H80CS00172 Program Year: 2022
Criteria
CAMcare’s internal controls over the special tests and provisions compliance area include the financial screening processes and related control activities to complete patient applications during financial screening, including reviewing and approving patient applications and calculating of scale ratings per patient based on annual income and family size.
Condition
During our testing of special tests and provisions, we noted control deficiencies related to the financial screening process; 5 out of 40 patient records sampled showed instances where the patient scale ratings were calculated incorrectly on the patient applications, and for 1 out of 40 samples, the sliding fee discount was applied to a patient visit for which the financial screening application process was not completed.
Cause
Financial screening personnel were not applying control procedures correctly in accordance with their financial screening process.
Effect
Possibility of inaccurate discounts given to patients and significant or material noncompliance with major federal programs.
Questioned Costs
None
Perspective Information
We tested a statistically valid sample of 40 patient visits out of a total population of 250+ uncompensated care program visits and determined that the audit finding represented a systemic problem.
Repeat Finding
This finding is not a repeated finding.
Recommendation
We recommend that management review the financial screening process in place and closely monitor the patient application process to emphasize the importance of correct implementation of control procedures.
Views of Responsible Officials
Management recognizes the deficiency; on November 29, 2023, CAMcare’s CEO, Jillian Hudspeth, and CFO, Christopher Bernardi, agreed with this finding, and explained that Management plans to offer additional training to the Financial Screening Department members and require the department manager to perform a periodic audit of applications.
Finding #: 2022-006 Special Tests and Provisions, Controls over Compliance – Significant Deficiency
Identification of Federal Program and Award
Program title: U.S. Department of Health and Human Services (DHHS): Public Health Services Act, Title III, Section 330 (Health Center Cluster)
CFDA #: 93.224/93.527 Award #: 17H80CS00172 Program Year: 2022
Criteria
CAMcare’s internal controls over the special tests and provisions compliance area include the financial screening processes and related control activities to complete patient applications during financial screening, including reviewing and approving patient applications and calculating of scale ratings per patient based on annual income and family size.
Condition
During our testing of special tests and provisions, we noted control deficiencies related to the financial screening process; 5 out of 40 patient records sampled showed instances where the patient scale ratings were calculated incorrectly on the patient applications, and for 1 out of 40 samples, the sliding fee discount was applied to a patient visit for which the financial screening application process was not completed.
Cause
Financial screening personnel were not applying control procedures correctly in accordance with their financial screening process.
Effect
Possibility of inaccurate discounts given to patients and significant or material noncompliance with major federal programs.
Questioned Costs
None
Perspective Information
We tested a statistically valid sample of 40 patient visits out of a total population of 250+ uncompensated care program visits and determined that the audit finding represented a systemic problem.
Repeat Finding
This finding is not a repeated finding.
Recommendation
We recommend that management review the financial screening process in place and closely monitor the patient application process to emphasize the importance of correct implementation of control procedures.
Views of Responsible Officials
Management recognizes the deficiency; on November 29, 2023, CAMcare’s CEO, Jillian Hudspeth, and CFO, Christopher Bernardi, agreed with this finding, and explained that Management plans to offer additional training to the Financial Screening Department members and require the department manager to perform a periodic audit of applications.