Finding Text
Assistance Listing, Federal Agency, and Program Name - 93.224, U.S. Department of Health and Human Services, Health Center Program, COVID-19 Health Center Program; 93.527, U.S. Department of Health and Human Services, COVID-19 Grants to New and Expanded Services Under the Health Center Program Federal Award Identification Number and Year - H80CS24134, 2020; H8FCS40356, 2021; H8GCS48255, 2022 Pass through Entity - N/A Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes 2022-004 Criteria - Per 2 CFR 200.303(a), nonfederal entities must establish and maintain effective internal controls over the Federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with the guidance in Standards for Internal Control in the Federal Government, issued by the Comptroller General of the United States, or the Internal Control Framework, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). In accordance with 42 CFR Section 51c 303(f), health centers must prepare and apply a sliding fee discount schedule (SFDS) so that the amounts owed for health center services by eligible patients are adjusted (discounted) based on the patient's ability to pay. Condition - The Organization lacked sufficient internal controls to ensure sliding fee discount applications were on file and included all of the necessary information regarding family size and income to support discount determinations made. Further, controls were not sufficient to ensure the correct sliding fee discount was applied. Questioned Costs - None If questioned costs are not determinable, description of why known questioned costs were undetermined or otherwise could not be reported - N/A Identification of How Questioned Costs Were Computed - N/A Context - During testing of 60 patients for compliance with special tests and provisions for sliding fee discounts, we noted 14 instances where the patient was undercharged for dental services, resulting in the program being overcharged. In addition, we noted 4 instances where patients were provided a sliding fee discount without an application on file or with key information for determining the discount, such as family size or income, missing from the application. Finally, we noted 4 patients who were overcharged for medical services provided based on family size and family income compared to the SFDS. Cause and Effect - An appropriate review of sliding fee applications and adjustments was not completed to ensure valid applications were maintained and the correct adjustment was applied. As a result, not all patients received the correct adjustment, and thus, the Organization did not comply with the related compliance requirement. Recommendation - We recommend the Organization implement controls, including levels of review, to ensure sliding fee applications are maintained and sliding fee adjustments are accurate based on correct family income and size. Views of Responsible Officials and Planned Corrective Actions - The Organization will implement controls to ensure sliding fee applications are maintained and sliding fee adjustments are based on correct family income and size.