Finding 1223576 (2025-001)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2025
Accepted
2026-07-13
Audit: 407001
Organization: Cowlitz Family Health Center (WA)
Auditor: APRIO LLP

AI Summary

  • Core Issue: The Health Center did not consistently apply the sliding fee discount schedule (SFDS), leading to incorrect patient charges.
  • Impacted Requirements: Compliance with Section 330 of the Public Health Service Act, which mandates proper SFDS application based on income verification.
  • Recommended Follow-Up: Strengthen controls by implementing system validations and conducting regular supervisory reviews to ensure accurate SFDS application.

Finding Text

Finding 2025-001 Special Tests and Provisions Significant Deficiency Health Center Program Cluster 93.224, 93.527 U.S. Department of Health and Human Services Federal Award Identification: H80CS00542, with multiple Notice of Awards issued during the year ended December 31, 2025 Federal program: Health Center Program Cluster Assistance listing number: 93.224, 93.527 Federal agency: U.S. Department of Health and Human Services Pass-through entity: Not applicable - direct award Award year: Year ended December 31, 2025 Criteria: Under Section 330 of the Public Health Service Act, health centers must prepare, approve, and consistently apply a sliding fee discount schedule (SFDS), supported by documented income verification, to ensure patient charges are adjusted based on the patient's ability to pay. Condition: During our audit, testing of 40 patient encounters identified 2 instances in which the SFDS was not applied in accordance with established requirements. These instances included the incorrect application of the sliding fee scale and the failure to apply the discount when required. As a result, certain patients were undercharged or overcharged for services received. Context: The control deficiency was identified during audit testing of patient encounters subject to sliding fee discount requirements for the Health Center Program Cluster. Cause: The Center did not consistently execute the internal control procedures designed to ensure proper application of the SFDS. Control activities relied on manual processes without sufficient system validation or supervisory review to detect and correct errors prior to billing. Effect: As a result, patient charges were not consistently calculated in accordance with sliding fee discount requirements. While the instances identified did not result in questioned costs, the deficiency increases the risk of noncompliance with the Special Tests and Provisions requirements, if not corrected timely. Known questioned costs: None. Repeat finding status: This is a new finding for the year ended December 31, 2025. Recommendation: The Center should strengthen controls over the sliding fee discount process by implementing system validations to support accurate SFDS application and performing periodic supervisory reviews to ensure consistent compliance with Section 330 requirements. Views of responsible officials: Management agrees with the finding. The Center has policies and procedures in place and has developed additional processes to ensure compliance.

Corrective Action Plan

Finding No. 2025-001 Federal Award Finding Significant Deficiency in Internal Control over Compliance Noncompliance over Special Tests and Provisions (Sliding Fee Discount Schedule) Cowlitz Family Health Center (CFHC) respectfully submits the following corrective action plan for the year ended December 31, 2025. Summary of finding: Testing of 40 patient encounters identified 2 instances in which the sliding fee discount schedule (SFDS) was not applied in accordance with established requirements. These instances included the incorrect application of the sliding fee scale and the failure to apply the discount when required. As a result, certain patients were undercharged or overcharged for services received. Planned corrective action: CFHC management concurs with the finding. CFHC has policies and procedures in place to ensure compliance. CFHC will provide additional training to the Patient Services Representatives and Billing Clerks to ensure the existing policies and procedures are followed. The CFHC Billing Manager will develop additional reviews to discover, correct, and educate when non-compliance is suspected. CFHC will provide targeted trainings as necessary for site level personnel. Monitoring and review will be an ongoing effort as the positions responsible for real-time compliance tend to be highly transitory. Additional review steps have already been implemented and will become part of the typical workflows to monitor compliance. Anticipated Completion Date: June 1, 2026 Contact Person: Jim Merrill, Chief Financial Officer Email: jmerrill@cfamhc.org Phone: 360-703-6701 Name and Address of Independent Public Accounting Firm: Aprio, LLP 3 Centerpointe Dr, Ste 300 Lake Oswego, OR 97035

Categories

Internal Control / Segregation of Duties Special Tests & Provisions Subrecipient Monitoring Significant Deficiency

Other Findings in this Audit

  • 1223575 2025-001
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
93.224 HEALTH CENTER PROGRAM $3.28M
10.557 WIC SPECIAL SUPPLEMENTAL NUTRITION PROGRAM FOR WOMEN, INFANTS, AND CHILDREN $769,554
14.239 HOME INVESTMENT PARTNERSHIPS PROGRAM $764,880
93.527 GRANTS FOR NEW AND EXPANDED SERVICES UNDER THE HEALTH CENTER PROGRAM $39,727
93.800 ORGANIZED APPROACHES TO INCREASE COLORECTAL CANCER SCREENING $24,650
93.217 FAMILY PLANNING SERVICES $23,270