Finding 1156004 (2024-001)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2024
Accepted
2025-09-29

AI Summary

  • Core Issue: The Center failed to accurately determine sliding fee discounts for some patients based on their ability to pay, violating federal guidelines.
  • Impacted Requirements: Compliance with the sliding fee scale as per DHHS poverty guidelines was not met, affecting the financial assistance provided to patients.
  • Recommended Follow-Up: Implement training for staff on discount calculations, establish regular supervisory reviews, and conduct internal audits to ensure ongoing compliance.

Finding Text

U.S. Department of Health and Human Services, COVID-19 Health Center Program Cluster (Assistance Listing Number 93.224/93.527) Item 2024-001 - Special Tests and Provisions Criteria Health centers are required to have a corresponding schedule of discounts applied and adjusted on the basis of patients' ability to pay and their eligibility. A patient's eligibility to pay is determined on the basis of the official poverty guideline, as revised by DHHS (42 CFR Sections 51c, 107(b)(5), 56.108(b)(5) and 56.303(f)). Statement of Condition While performing our audit, we noted that the Center did not properly determine the sliding fee discount category given to certain patients selected for testing based on the sliding fee scale in effect for the year ended December 31, 2024. Cause The condition can be attributed to human error and the lack of internal controls to review and ensure that the proper sliding fee documentation is being maintained and applied. Effect The Center did not comply with the determination of sliding fee discounts based on the federal poverty guidelines in effect for the year ended December 31, 2024. In addition, the Center may not have properly calculated the sliding fee or discount given to the patients and the discount given, if any, may not have been based on the patient's ability to pay. Questioned Costs None Context While performing our audit, we noted that the Center did not properly determine the sliding fee discount category given to two out of fifty-five patients selected for testing based on the sliding fee scale in effect for the year ended December 31, 2024. Identification as a Repeat Finding This is not a repeat finding. Recommendation We recommend that proper training be given to employees at registration to ensure that the sliding fee discounts are being properly calculated. Supervisors should monitor and review the sliding fee calculations on a periodic basis to ensure compliance with the sliding fee scale. In addition, management should conduct internal audits to ensure the sliding fee is calculated properly. Views of Responsible Official Employees received training in January 2025 to ensure the sliding fee discounts are correctly applied. Additionally, DVCH is planning an annual refresher training for staff. The Patient Account Counselor Team Leader conducts a monthly internal audit of sliding fee discounts. Findings are reviewed with staff and the Director of Revenue Cycle Management. The audit samples each site and department to ensure accuracy across the organization. DVCH will explore the possibility of engineering a change in our practice management system to facilitate and remind the registration and revenue cycle staff to complete the sliding fee calculations when needed

Corrective Action Plan

Corrective Action Plan September 26th , 2025 Health Resources and Services Administration Delaware Valley Community Health, Inc. and Delaware Valley Community Support Network Trust respectfully submit the following corrective action plan for the year ended December 31, 2024. CohnReznick LLP 1301 Avenue of the Americas New York, NY 10019 Audit Period: December 31, 2024 The finding from the December 31, 2024 schedule of findings and questioned costs is discussed below. FINDINGS – FEDERAL AWARDS PROGRAM AUDIT U.S. Department of Health and Human Services, COVID‐19 Health Centers Program Cluster (Assistance Listing Number 93.224/93.527) Finding 2024‐001 – Special Tests and Provisions SIGNIFICANT DEFICIENCY Recommendation We recommend that proper training be given to employees at registration to ensure that the sliding fee discounts are being properly calculated. Supervisors should monitor and review the sliding fee calculations on a periodic basis to ensure compliance with the sliding fee scale. In addition, management should conduct internal audits to ensure the sliding fee is calculated properly. Action Taken Employees received training in January 2025 to ensure the sliding fee discounts are correctly applied. Additionally, DVCH is planning an annual refresher training for staff for the first quarter of 2026. The Patient Account Counselor Team Leader conducts a monthly internal audit, which began in the first quarter of 2025, of sliding fee discount. In September of 2025, the audit was adjusted to collect additional actionable information. The findings from the internal audit are reviewed with staff, the Director of Revenue Cycle Management, and the Director of Operations. The audit samples each site and department to ensure accuracy across the organization. DVCH is exploring the possibility of engineering a change in our electronic practice management system to facilitate and remind the registration and revenue cycle staff to complete the sliding fee calculations when needed. This discovery process began in September 2025. If the Health Resources and Services Administration has questions regarding this plan, please call Ryan Taylor, Chief Financial Officer at 267-240-2578.

Categories

Special Tests & Provisions Eligibility Internal Control / Segregation of Duties

Other Findings in this Audit

  • 1156000 2024-001
    Material Weakness Repeat
  • 1156001 2024-001
    Material Weakness Repeat
  • 1156002 2024-001
    Material Weakness Repeat
  • 1156003 2024-001
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
93.530 Affordable Care Act - Teaching Health Center Graduate Medical Education Payments Program $315,196
93.224 Consolidated Health Centers (community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) $205,363
93.914 Hiv Emergency Relief Project Grants $162,262
93.988 Cooperative Agreements for State-Based Diabetes Control Programs and Evaluation of Surveillance Systems $110,231
93.527 Affordable Care Act (aca) Grants for New and Expanded Services Under the Health Center Program $34,440
93.268 Immunization Cooperative Agreements $33,953
93.778 Medical Assistance Program $26,491
93.243 Substance Abuse and Mental Health Services_projects of Regional and National Significance $10,451
93.297 Teenage Pregnancy Prevention Program $7,000
93.866 Aging Research $4,800
93.071 Medicare Enrollment Assistance Program $50