Finding 1201604 (2025-002)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2025
Accepted
2026-03-30
Audit: 396169
Organization: Circle the City (AZ)
Auditor: CBIZ CPAS PC

AI Summary

  • Core Issue: Inaccurate calculation of sliding fee discounts for eligible patients on five out of 40 claims tested.
  • Impacted Requirements: Health Centers must have a proper sliding fee discount schedule and ensure it is reviewed and approved before billing.
  • Recommended Follow-Up: Implement a supervisory review process for sliding fee discounts and ensure documentation of approvals prior to billing.

Finding Text

Item: 2025-002 Assistance Listing Number: 93.224 Program: Health Center Program Federal Agency: U.S. Department of Health and Human Services Contract Number: 24H80CS28365; H8JCS54690; 21H8HCS44987 Award Year: June 1, 2024 to May 31, 2025; December 1, 2024 to November 30, 2025 September 1, 2023 to August 31, 2025 Compliance Requirement: Special Tests and Provisions Criteria: Health Centers must prepare and apply a sliding fee discount schedule so that the amounts owed for health center services by eligible patients are adjusted (discounted) based on the patient’s ability to pay. Condition: For five claims tested, the discount for eligible patients was inaccurately calculated and billed. Questioned Costs: N/A Context: In a population of 7,227 claims, we conducted a non-statistical sample of 40 claims. For five claims tested, we noted the discount for eligible patients was inaccurately calculated and billed. We also noted no evidence of management review or approval of the sliding fee discount applied. Effect: The system of internal controls was not properly implemented to ensure review and approval of the sliding fees discounts applied prior to billing the eligible patients. This is deemed to be a material weaknesses in internal control over compliance. Cause: The Organization does not have a supervisory review process implemented for application of the sliding fee discount. Identification as a Repeat Finding: Not a repeat finding. Recommendation: The Organization should implement additional controls to ensure claims where a sliding fee discount is applied are reviewed and approved prior to billing the patient. This review and approval should be clearly documented. Views of Responsible Officials: Management of the Organization concurs with the finding. See Corrective Action Plan.

Corrective Action Plan

Item: 2025-002 Assistance Listing Number: 93.224 Programs: Health Center Program Federal Agency: U.S. Department of Health and Human Services Pass-Through Agency: N/A Contract Number: 24H80CS28365; H8JCS54690; 21H8HCS44987 Award Year: June 1, 2024 to May 31, 2025; December 1, 2024 to November 30, 2025; September 1, 2023 to August 31, 2025 Compliance Requirement: Special Tests and Provisions Criteria: Health Centers must prepare and apply a sliding fee discount schedule so that the amounts owed for health center services by eligible patients are adjusted (discounted) based on the patient’s ability to pay. Condition: For five claims tested, the discount for eligible patients was inaccurately calculated and billed. Name of Contact Person: Michele Grebisz, CFO Phone Number: (602)776-0776 Anticipated Completion Date: March 31, 2026 Views of Responsible Officials and Corrective Actions: Management agrees with the finding and will implement additional controls to ensure sliding fee discounts applied are reviewed and approved before patients are billed. Management will ensure this additional process includes clearly documenting the review and approval.

Categories

Special Tests & Provisions Material Weakness Internal Control / Segregation of Duties

Programs in Audit

ALN Program Name Expenditures
93.224 HEALTH CENTER PROGRAM (COMMUNITY HEALTH CENTERS, MIGRANT HEALTH CENTERS, HEALTH CARE FOR THE HOMELESS, AND PUBLIC HOUSING PRIMARY CARE) $4.39M
21.027 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $243,250