Finding 1227745 (2026-001)

Material Weakness Repeat Finding

Requirement

Questioned Costs

Year

2026

Accepted

2026-08-25

Audit: 409718

Organization: Moses Lake Community Health Center (WA)

Auditor: CLARK NUBER PS

AI Summary

Core Issue: There is a significant deficiency in internal controls over compliance related to the sliding fee discount schedule, leading to inconsistent patient billing.
Impacted Requirements: The Organization failed to meet internal control requirements outlined in Title 2 U.S. CFR 200, which mandates reasonable assurance of compliance with federal award conditions.
Recommended Follow-Up: Management should create a monitoring plan for sliding scale fees, enhance oversight after changes, and provide additional training for billing staff during transitions.

Finding Text

Finding 2026-01 Significant deficiency in internal controls over compliance related to special tests and provisions. Federal Agency: Department of Health and Human Services Program Titles: Health Center Program Cluster Assistance Listing Number: 93.224 and 93.527 Award Numbers: 6 H80CS00702‐24‐02, 1 H8NCS54184‐01‐00, and 6 H80CS00702‐23‐04 Award Periods: April 1, 2024 through August 31, 2026 Criteria Internal controls requirements contained in Title 2 U.S. Code of Federal Regulations (CFR) 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Subpart D requires recipients of federal awards to adopt internal controls over compliance requirements that provide a reasonable assurance that compliance requirements are met. The Health Center Program Cluster requires that health centers prepare and apply a sliding fee discount schedule. Condition/Context for Evaluation The Organization does not have sufficient internal controls to ensure that the allowable and the applicable sliding fee discount schedule is applied. For six of forty sliding fee discounts selected for testing, the Organization billed patients inconsistent with their sliding fee discount schedule in effect at the time of the patient visit. The errors occurred after transition to a new sliding fee discount schedule and did not include charging fees in excess of a reasonable sliding fee discount schedule. Questioned Costs None noted. Cause The Organization has insufficient monitoring controls to ensure that a change in the slide fee scale is properly and consistently applied by the patient billing software. Effect Patients were charged fees inconsistent with the sliding fee discount schedule in effect at the time of service. Repeat Finding Not applicable. Recommendation We recommend that management develop a plan to monitor sliding scale fees applied on an ongoing basis, and that this plan include increased monitoring and sampling of the slides scale fees applied in the period after a change is implemented. Additionally, we recommend increased training for billers during a transition to a new sliding scale to ensure billers are able to identify errors. Views of Responsible Officials Management agrees that even though controls supported a mostly accurate implementation of the new sliding fee scale, controls did not catch and correct some cases where the old slide scale was incorrectly applied.

Corrective Action Plan

Corrective action planned: Management concurs with the finding and recognizes the importance of consistently applying the correct sliding fee discount schedule in effect at the time services are rendered. To address this finding, the organization has implemented enhanced monitoring and training controls over the application of the sliding fee discount schedules. The Director of Patient Services (or designee) will perform monthly audits of 25 randomly selected patients accounts that received a sliding fee discount to verify that the correct discount schedule was applied and that the patient responsibility was calculated accurately. In addition, for any future changes to the sliding fee discount schedule, management will implement a transition review process that includes: • Verification that the updated fee schedule is accurately loaded into the billing system prior to the effective date and old fee schedules are inactivated. • Additional training for billing staff before implementation of any revised sliding fee schedule. • Continued monthly audits of sliding fee discounted patient accounts. • Quarterly reporting of audit results to Chief Financial Officer, to identify recurring issues and ensure corrective actions taken are effective. Anticipated completion date: July 31, 2026

Other Findings in this Audit

1227743 2026-001

Material Weakness Repeat
1227744 2026-001

Material Weakness Repeat

Programs in Audit

ALN	Program Name	Expenditures
10.557	WIC SPECIAL SUPPLEMENTAL NUTRITION PROGRAM FOR WOMEN, INFANTS, AND CHILDREN	$1.02M
93.224	HEALTH CENTER PROGRAM	$224,082
93.527	GRANTS FOR NEW AND EXPANDED SERVICES UNDER THE HEALTH CENTER PROGRAM	$13,865