Finding 1206226 (2025-001)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2025
Accepted
2026-04-09
Audit: 398192
Organization: Care Alliance Health Center (CT)
Auditor: COHNREZNICK

AI Summary

  • Core Issue: The Organization lacks proper documentation and controls for sliding fee scale discounts, leading to incorrect calculations.
  • Impacted Requirements: Compliance with federal guidelines for determining patient eligibility and applying discounts is not being met.
  • Recommended Follow-Up: Implement stronger internal controls to ensure accurate calculations and documentation of sliding fee discounts.

Finding Text

Finding 2025.001: Special Tests and Provisions - Sliding Fee Scale Documentation - Material Weakness Name of Federal Agency: U.S. Department of Health and Human Services Federal Program Names: Health Center Program Cluster: Health Center Program, Grants for New and Expanded Services under the Health Center Program, COVID-19 - Grants for New and Expanded Services under the Health Center Program Federal Assistance Listing Numbers: 93.224 and 93.527 Federal Award Identification Number and Year: H80CS00029 - 2024 and 2025, H2ECS50128 - 2024 and 2025, H8LCS51483 - 2024 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)). The Organization should be implementing and monitoring procedures to properly determine, calculate and review sliding fee discounts issued to patients in accordance with the Organization's sliding fee scale. Condition The Organization did not always have the proper slide fee documentation readily available to ensure the proper slide fee discount was applied based on approved policies or the discount was calculated incorrectly. Cause The Organization did not have adequate internal controls in place to effectively ensure that all sliding fee discounts were properly calculated based on approved documentation. Effect or Potential Effect The Organization did not comply with the appropriate rules and regulations as per the Uniform Guidance. Questioned Costs None reported. Context A test of 40 sliding fee discount transactions was performed and resulted in 17 instances where the Organization was unable to provide approved documentation, or the sliding fee discount was calculated incorrectly. Our sample was a statistically valid sample. Identification of Repeat Finding Yes, see prior year Finding 2024.001 Recommendation The Organization should establish a system of internal controls to ensure that all sliding fee discounts are properly calculated and supported based on family size and income. Views of Responsible Officials and Planned Corrective Actions Management agrees with the audit finding and will strengthen internal controls and accountability to correct the deficiency.

Corrective Action Plan

Care Alliance Health Center, Inc. respectfully submits the following corrective action plan for the year ended October 31, 2025. CohnReznick LLP 350 Church Street Hartford, CT 06103 Audit Period: October 31, 2025 The findings from the October 31, 2025 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the number assigned in the schedule. Federal Award Findings: Finding 2025.001 - Special Tests and Provisions - Sliding Fee Scale Documentation Recommendation The Organization should establish a system of internal controls to ensure that all sliding fee discounts are properly calculated and supported based on family size and income. Action Taken FY 2025 Corrective Actions and Objectives Documented Process, Procedures and Policies • By June 30, 2026, Care Alliance will update, standardize, and implement a unified, documented workflow for full-fee collection at check-in for all encounters. • Key Performance Indicators (KPI) • ≥90% of self-pay encounters have documented collection attempt • 100% of quarterly review cycles by October 31, 2026. • By April 15, 2026, Finance and Operations will develop a concise list of commonly used CPT/HCPCS procedure codes with associated full fee amounts for Patient Services Representatives (PSRs). The list will be updated quarterly. • KPIs • 100% staff acknowledgment of list each quarter • ≥85% accurate fee quotes of random sampling • By May 1, 2026, Finance and Operations will review and update finance policies governing full-payment determination and collections (FS 106 Sliding Fee Scale Discount Program and FS 107 Billing, Credit, and Collection). • KPIs • 100% staff acknowledgment of updated policies • ≥95% compliant monthly audit of SFS documentation (random sampling) Training and Education • By June 30, 2026, Care Alliance will provide training to front desk staff members responsible for determining eligibility and applying sliding fee discounts. Training will cover documentation requirements, verification of family size/income, and correct SFS application. • KPIs • 100% Staff Training and Education Sign- Off • 100% Completion of annual competency for SFS • By May 31, 2026, Operations will implement a process that ensures Sliding Fee Scale (SFS)/self-pay indicators, Federal Poverty Level (FPL) are accurately entered and maintained for all visits, across all guarantor accounts. • KPIs • ≥90% of self-pay encounters have documented collection attempt • ≥85% accurate fee quotes of random sampling • By April 30, 2026, PSR will use standardized documentation during collections (amount owed, partial payments, attempts, patient ability to pay) for every applicable visit and incorporate into monthly audits. • KPIs • ≥90% documentation compliance of sampled encounters • By July 31, 2026, Finance will clarify treatment and procedures of bad debt previously written off and integrate post-write-off recovery efforts into policy and monthly reporting. • KPIs • 100% staff acknowledgment of updated policies Review and Auditing By May 1, 2026, and continuing throughout FY26, the Revenue Cycle Manager and Controller will conduct monthly audits to verify that all Sliding Fee Scale (SFS) discounts are accurately calculated, properly supported, and fully documented in accordance with FS 106. Additionally, the Controller will conduct quarterly reviews to evaluate overall compliance, identify areas for improvement, and assess the effectiveness of the sliding scale fee program in meeting patient needs and federal guidelines. Responsible Parties and Reporting Cadence • Controller and Director of Operations: Owns policy updates (FS 106/FS 107), quarterly documentation reviews, and oversight of FPL table updates. • Revenue Cycle Manager: Monitors adherence to workflow, conducts monthly audits, and drives corrective actions with Clinical Support Manager. Maintains the common procedures fee list and coordinates quarterly updates. • Clinical Support/Patient Access Manager (PSR Manager): Oversees PSR training, documentation compliance, and daily operations. Provides staff coaching and remediation based on monthly audit results. If there are any question regarding this plan, please e-mail Dr. Derrick Howell at dhowell@carealliance.org. Sincerely, Dr. Derrick Howell CFO

Categories

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

Other Findings in this Audit

  • 1206224 2025-001
    Material Weakness Repeat
  • 1206225 2025-001
    Material Weakness Repeat

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) $4.92M
93.526 GRANTS FOR CAPITAL DEVELOPMENT IN HEALTH CENTERS $644,905
93.918 GRANTS TO PROVIDE OUTPATIENT EARLY INTERVENTION SERVICES WITH RESPECT TO HIV DISEASE $5,686
93.527 GRANTS FOR NEW AND EXPANDED SERVICES UNDER THE HEALTH CENTER PROGRAM $1,834