FAC Explorer

Finding 1229049 (2025-001)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2025
Accepted
2026-09-08
Audit: 410508
Organization: Partnership Community Health Center, Inc. (WI)
Auditor: WIPFLI LLP

AI Summary

  • Core Issue: One out of 40 eligibility determinations for sliding fee discounts lacked proper internal control review.
  • Impacted Requirements: Compliance with 42 CFR Sections 51c.303(e), (f), and (g) and Uniform Guidance for internal controls.
  • Recommended Follow-Up: Review and enhance the internal approval process for sliding fee scale calculations to ensure accuracy and compliance.

Finding Text

Finding No. 2025-001: Special Tests and Provision - Sliding Fee Scale Discounts Program Affected: Direct Award - Department of Health and Human Services: Health Center Program Cluster (Health Center Program AL No. 93.224). Grant No. H80CS04197, with grant periods May 1, 2024 through April 30, 2025, and May 1, 2025 through April 30, 2026. Questioned Costs: None Condition: The Health Center's sliding fee scale policy provides for the application of discounts to eligible patients based on the ability to pay. The Health Center has designed an internal control to provide a review and approval of eligibility determinations within the established sliding fee scale based on income and family size. During our testing of participants, it was noted that one out of the 40 individuals sampled and tested did not have evidence that the internal control designed had been applied to the determination of eligibility within the sliding fee scale framework. However, it was verified that the individual was charged correctly. Therefore, we did not identify any noncompliance issues related to this internal control deficiency. Criteria: 42 CFR Sections 51c.303(e), (f), and (g) require a health center to apply sliding fee discounts to patients consistent with its sliding fee discount schedule. The Uniform Guidance requires grantees to design and implement internal controls over compliance to prevent, or detect and correct noncompliance with compliance requirements. Cause: The Health Center's monitoring and approval process did not occur for one individual. Effect: The internal control did not operate effectively and that failure created a risk that individuals could be charged incorrectly. Recommendation: Wipfli LLP recommends the Health Center review its internal process for approval of the sliding fee scale calculation and determine that the review is performed to prevent, or detect and correct errors in data entry. Views of responsible officials: We agree with the finding and had already implemented corrective action during the fiscal year under audit.

Corrective Action Plan

Corrective Action Plan: To address the documentation deficiency related to the application of internal controls for sliding fee scale eligibility determinations, Partnership Community Health Center will reinforce and monitor the following ongoing practices: 1. Staff Training: Ongoing and refresher training is provided to all staff responsible for processing sliding fee scale applications. Training emphasizes the importance of documenting each step in the eligibility review and approval process. 2. Checklist Utilization: Staff continue to use the established checklist for each sliding fee scale application, ensuring all required steps in the eligibility review and approval process are documented, initialed, and dated. 3. Weekly Audits: Patient Services and Outreach Managers conduct regular weekly audits of a sample of sliding fee scale applications to verify that documentation of internal control procedures is consistently maintained. Any identified issues are addressed promptly with targeted corrective actions as needed. 4. Ongoing Monitoring: Results of the weekly audits are reviewed during monthly compliance meetings to ensure that corrective actions are implemented and sustained. Additional Context: This was an isolated case involving a staff member who was in training at the time of the incident and is no longer with the organization. All current staff have completed required training, and ongoing refresher sessions are in place to prevent recurrence. Person(s) Responsible: • Patient Services and Outreach Managers (for weekly checklist oversight, audits, and corrective actions) • Compliance Officer • CFO and PCHC Billing Timing for Implementation: • These practices are ongoing. Continued monitoring and reinforcement will ensure sustained compliance.

Categories

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

Other Findings in this Audit

  • 1229048 2025-001
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
93.224 CONSOLIDATED HEALTH CENTERS (COMMUNITY HEALTH CENTERS, MIGRANT HEALTH CENTERS, HEALTH CARE FOR THE HOMELESS, AND PUBLIC HOUSING PRIMARY CARE) $542,696
93.268 IMMUNIZATION COOPERATIVE AGREEMENTS $12,498