Finding 2025-001 — Special Tests and Provisions – Sliding Fee Discount Program Federal Program: Health Center Program Cluster, ALN 93.224 Federal Agency: U.S. Department of Health and Human Services (Health Resources and Services Administration) Condition (as reported): The Organization’s Board-approved sliding fee discount schedule was not configured correctly within the eClinicalWorks (eCW) billing system, resulting in patient sliding fee discounts that were not calculated in accordance with the Organization’s approved schedule. Name of Contact Person Responsible for Corrective Action: Hope Beemer, Chief Financial Officer 513.318.1188 | hope.beemer@centerpointhealth.org Corrective Action Taken: The Organization has corrected the condition identified in the finding. Specifically: • In 2025, Centerpoint Health utilized an outside vendor for billing services. To strengthen internal oversight and accountability, billing was brought in-house in January 2026 with the hiring of a Director of Revenue Cycle Management. By April 2026, all billing and revenue cycle operations were fully transitioned to Centerpoint Health’s internal team. • The Board of Directors reviewed and approved an updated sliding fee discount schedule in May 2026, which was implemented in the eClinicalWorks (eCW) billing system with an effective date of February 1, 2026. • Prior to implementation, management verified that the approved schedule was accurately configured in eCW by comparing system-generated discounts to the Board-approved schedule across each discount tier. • Patient encounters affected during 2025 were reviewed and discounts are adjusted where necessary. This was completed by August 2026. Ongoing Controls to Prevent Recurrence: • Any change to the sliding fee discount schedule in eCW requires a secondary, independent review and approval before the change is activated. • Management performs a quarterly reconciliation of system-generated sliding fee discounts to the current Board-approved schedule and investigates and resolves any exceptions. • The sliding fee discount schedule is reviewed and approved by the Board of Directors at least annually and is updated for changes in the Federal Poverty Guidelines. • Billing and front-desk staff receive annual training on the sliding fee discount policy and schedule. Anticipated Completion Date: • Completed. The updated Board-approved sliding fee discount schedule was implemented effective February 1, 2026, and the ongoing monitoring controls described above are in effect.