Finding 12275 (2022-003)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2022
Accepted
2023-05-07

AI Summary

  • Core Issue: The Center failed to accurately determine sliding fee discounts for some patients, violating federal guidelines.
  • Impacted Requirements: Compliance with the sliding fee scale based on patients' ability to pay, as mandated by DHHS regulations.
  • Recommended Follow-Up: Provide training for registration staff and implement regular supervisory reviews and internal audits to ensure proper application of sliding fee discounts.

Finding Text

Item 2022-003 - Special Tests and Provisions U.S. Department of Health and Human Services, COVID-19 Health Center Program Cluster (Assistance Listing Number 93.224/93.527) 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 Center should be implementing and monitoring procedures to properly determine, calculate and review sliding fee discounts issued to patients in accordance with the Center's sliding fee scale. Statement of Condition While performing our audit, we noted that the Center did not properly determine the sliding fee discount category given to certain patients selected for testing based on the sliding fee scale in effect for the year ended February 28, 2022. Questioned Costs None Context While performing our audit, we noted that the Center did not properly determine the sliding fee discount category given to two out of the sixty patients selected for testing based on the sliding fee scale in effect for the year ended February 28, 2022. Cause The condition can be attributed to human error and the lack of internal controls to review and ensure that the proper sliding fee documentation is being maintained and applied. Effect The Center did not comply with the determination of sliding fee discounts based on the federal poverty guidelines in effect for the year ended February 28, 2022. In addition, the Center may not have properly calculated the sliding fee or discount given to the patients and the discount given, if any, may not have been based on the patient's ability to pay. Identification as a Repeat Finding Condition is a repeat finding - see 2021-003. Recommendation We recommend that proper training be given to employees at registration to ensure that the sliding fee discounts be monitored and reviewed by a supervisor on a periodic basis to ensure compliance with the sliding fee scale. In addition, management should conduct internal audits to ensure the sliding fee scale is calculated properly. Views of Responsible Official The Center concurs with this finding and will ensure that controls are established to ensure proper training and review of the sliding fee discounts.

Corrective Action Plan

CORRECTIVE ACTION PLAN March 27, 2023 Health Resources and Services Administration St. Thomas East End Medical Center Corporation and Affiliate respectfully submits the following corrective action plan for the year ended February 28, 2022. ____________________________________________________________________________________ CohnReznick LLP 1301 Avenue of the Americas New York, NY 10019 Audit Period: February 28, 2022 The findings from the February 28, 2022 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the number assigned in the schedule. FINDINGS ? FINANCIAL STATEMENT AUDIT Finding 2022-001 ? Pension MATERIAL WEAKNESS Recommendation We recommend that the Center implement policies and procedures that allow for the timely payments of the pension plan payments. Action Taken & Completion Date The Center is working hard to make sure that all pension payments are made on time by strengthening our controls to ensure that the pension payments process is monitored properly. Completion Date October 1, 2023 Finding 2022-002 ? Account Analyses MATERIAL WEAKNESS Recommendation We recommend that the Center ensure that all accounting records are analyzed and reconciled on a monthly basis. Action Taken & Completion Date Management is working with staff to ensure that all accounting records are reviewed, analyzed and reconciled on a monthly basis. A new Chief Financial Officer started working at the Center on April 3, 2023. We are in the process of working together to create tighter protocols within the financial department. COMPLETEION DATE: October 1, 2023 FINDINGS ? FEDERAL AWARDS PROGRAM AUDIT U.S. Department of Health and Human Services, COVID-19 Health Centers Program Cluster (Assistance Listing Number 93.224/93.527) Finding 2022-003 ? Special Tests and Provisions MATERIAL WEAKNESS Recommendation We recommend that proper training be given to employees at registration to ensure that the sliding fee discounts be monitored and reviewed by a supervisor on a periodic basis to ensure compliance with the sliding fee scale. In addition, management should conduct internal audits to ensure the sliding fee scale is calculated properly. Action Taken St. Thomas East End Medical Center has already provided some training to staff regarding the Sliding Fee Discount Program and is in the process of developing a training area within the Business Office to ensure the staff is appropriately trained regarding the scale. We are also creating new processes for quality improvement and compliance. Completion Date October 1, 2023 Finding 2022-004 ? Reporting MATERIAL WEAKNESS Recommendation We recommend that the Center establish controls to ensure all accounting records are analyzed and proper support is available in order to ensure that the financial statement audit is submitted on a timely basis to the federal government. Action Taken & Completion Date St. Thomas East End Medical Center is currently onboarding new leadership. As a part of this change, we are working diligently to ensure that the Business Office is restructured, to include development of quality controls, appropriate processes and procedures surrounding analysis and reconciliation of accounts. We are also working with team to ensure that all reporting is done on time. Completion October 1, 2023 If the Health Resources and Services Administration has questions regarding this plan, please call Tess G. Richards, M.D. Interim Executive Director at 340-775-3700, ext. 3023. Sincerely yours,

Categories

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

Other Findings in this Audit

  • 12276 2022-004
    Material Weakness
  • 12277 2022-003
    Material Weakness Repeat
  • 12278 2022-004
    Material Weakness
  • 12279 2022-003
    Material Weakness Repeat
  • 12280 2022-004
    Material Weakness
  • 588717 2022-003
    Material Weakness Repeat
  • 588718 2022-004
    Material Weakness
  • 588719 2022-003
    Material Weakness Repeat
  • 588720 2022-004
    Material Weakness
  • 588721 2022-003
    Material Weakness Repeat
  • 588722 2022-004
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
93.527 Grants for New and Expanded Services Under the Health Center Program $1.18M
93.224 Consolidated Health Centers (community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) $1.01M
93.498 Provider Relief Fund and American Rescue Plan (arp) Rural Distribution $185,737
93.461 Covid-19 Testing for the Uninsured $21,040
93.917 Hiv Care Formula Grants $5,924