Identification of the Federal Program: Grantor: United States Department of Health and Human Services Program Name: Health Center Program Cluster Assistance Listing No.: 93.224 – Health Center Program; 93.527 – Grants for New and Expanded Services under the Health Center Program Name of responsible ...
Identification of the Federal Program: Grantor: United States Department of Health and Human Services Program Name: Health Center Program Cluster Assistance Listing No.: 93.224 – Health Center Program; 93.527 – Grants for New and Expanded Services under the Health Center Program Name of responsible official: James Geraghty Associate Vice President, Faculty Practice Group Phone: (718) 430-3255 Email: james.geraghty@einsteinmed.edu Projected completion date: October 1, 2025 Condition In accordance with Title 2 U.S. Code of Federal Regulations, Part 200.303, Internal controls, “Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.” The Health System was unable to demonstrate that internal controls were operating effectively throughout the audit period to ensure the proper application of its sliding fee discount schedule (SFDS). During testing, three patients were charged self-pay balances when, based on the applicable sliding fee discount schedule, those charges should have been discounted. The exceptions occurred prior to the implementation of corrective actions associated with the prior-year finding. Management implemented enhanced controls effective October 1, 2025; however, the identified exceptions demonstrate that controls were not operating effectively during a portion of the audit period. Views of responsible officials and planned corrective actions Management concurs with the audit finding and will continue to monitor the effectiveness of the corrective actions implemented October 1, 2025. Standardized procedures have been implemented to strengthen patient screening and enrollment, including controls to ensure the timely collection and documentation of income and family size. To reinforce compliance with SFDS requirements for eligibility determination, documentation, and record retention, a policy was adopted requiring reviews on the day before the patient visit, during the visit, and the day after the visit, as well as periodic retrospective reviews. Staff received regular training on SFDS eligibility, determination, and documentation requirements. Additional corrective actions include a targeted review of patients who had insurance but lacked documented Federal Poverty Level (FPL) information to determine whether any were inappropriately assigned self-pay balances and to ensure appropriate corrective action where necessary. Management will perform monthly monitoring of SFDS determinations, including review of a sample of patient accounts, to verify eligibility documentation, FPL determination, and application of the appropriate discount. Identified exceptions will be investigated and corrected timely, with results documented and reported to responsible management.