Finding Text
Finding 2024-001 – Special Tests and Provisions – Significant Deficiency in Internal Control over
Compliance
Federal Program: U.S. Department of Health and Human Services Health Center
Program Cluster (Federal Assistance Listing # 93.224/93.527)
Federal Agency: U.S. Department of Health and Human Services
Award Year: 2023-2024
Criteria:
The recipient is required to comply with specific federal regulations and provisions outlined in 2 CFR Part 200, particularly those related to special tests and provisions for the Health Center Program Cluster. This includes maintaining an effective internal control environment to ensure sliding fee discounts are applied to patient charges consistent with the recipients sliding fee discount schedule.
Condition/Cause:
During the audit, it was identified that the implementation of the new electronic health record system significantly impacted the Organization’s control environment. As a result, the control system did not consistently apply the appropriate sliding fee discounts for patients based on qualification criteria.
Effect:
Certain patients were billed amounts less than the amounts defined by the sliding fee discount schedule due to the control system inconsistencies.
Questioned costs:
None since patients were billed amounts less than the sliding fee discount schedule.
Context:
We selected a sample of 25 patient visits from a statistically valid population of patients potentially eligible for benefits under the sliding fee schedule during the fiscal year ended June 30, 2024. In 11 out of 25 samples tested, the Organization’s system limitations resulted in patients being billed less than the amounts defined by the sliding fee discount schedule.
Repeat Finding:
This is not a repeat finding.
Recommendation:
We recommend the Organization ensures its third-party IT service provider appropriately configures its electronic health record system for compliance with federal award requirements, and that staff using the electronic health record system are provided comprehensive training of the system to ensure that the sliding fee scale is accurately applied to all qualifying program participants. Additionally, we would recommend the Organization perform regular reviews to ensure there are no issues with the system.
Views of responsible officials:
The Organization has started conversations with its third-party IT service provide who facilitated the
implementation of its electronic health record system, to address concerns regarding the system’s current configuration. It plans to collaborate with the provider to rectify the identified limitations within the system, as well as update its policies and procedures to include regular system reviews to ensure the system is effectively operating.