Finding 1224319 (2025-001)

Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Health Center Program Cluster Assistance Listing Number: 93.224 / 93.527 Federal Award Identification Number and Year: H8000028 – 2024 Pass-Through Agency: Not Applicable Award Period: January 1, 2025 – December 31, 2025 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matter Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award states that Health centers must prepare and apply a sliding fee discount schedule (SFDS) so that amounts owed for health center services by eligible patients are adjusted based on the patient’s ability to pay, including: (a) discounts applied to individuals/families with annual incomes at or below 200% of Federal Poverty Guidelines (FPG); (b) full discount or nominal charge for individuals/families at or below 100% of FPG; (c) discounts based on gradations in family size and income for those above 100% and at or below 200% of FPG; and (d) no discount applied for those above 200% of FPG. Condition: During our testing, we noted the following two instances of noncompliance in the sample of forty patient files tested: •In one patient file selected for testing, the sliding fee discount applied was incorrect due to the patient’s income not being entered correctly in Epic, resulting in an inaccurate FPL calculation and associated discount classification. •In one patient file selected for testing, based on support provided and the SFDS, an incorrect discount class was applied and the County was not able to provide documentation demonstrating how annual income/household size supported the applied discount classification. Questioned costs: None Context: The eligible individuals consist of one population, and a total of 40 patients were selected from the health care system. The sample sizes were based on guidance from chapter 11 of the AICPA Audit Guide, Government Auditing Standards and Single Audits. Of the 40 selections, errors were noted in two of the cases (see condition section above for more detail). Cause: The root cause of this finding is the inconsistent application of the defined “annual income” standard for low‑income patients and household size across the team. For patients with unstable employment or multiple income sources, annual income calculations were not applied consistently, resulting in inaccuracies and inconsistent approach. Effect: Improper calculation of patient's income/improper input of patient's income to the EPIC system causes the improper sliding fee discount to be applied to their account. This could cause the County to not follow their sliding fee discount scale and patients paying incorrect amounts for services provided. Repeat Finding: No Recommendation: We recommend NorthPoint continue to implement their new automated process of uploading applications to EPIC to avoid human error when it comes to income amounts. We also recommend that NorthPoint creates more procedures/policy over documentation of the income calculations/conversation that takes place with the patient. Views of responsible officials: Hennepin County has reviewed and agrees with the findings and recommendations.