Finding 1236209 (2025-002)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2025
Accepted
2026-09-23
Audit: 411822
Organization: Waikiki Health (HI)
Auditor: COHNREZNICK LLP

AI Summary

  • Core Issue: The Center failed to consistently apply the correct sliding fee discounts due to inadequate documentation and internal controls.
  • Impacted Requirements: Compliance with federal guidelines for determining patient eligibility and applying sliding fee discounts was not met.
  • Recommended Follow-Up: Implement stronger internal controls and monitoring systems to ensure accurate calculation and documentation of sliding fee discounts.

Finding Text

Finding 2025.002: Special Tests and Provisions - Material Weakness Name of Federal Agency: U.S. Department of Health and Human Services Federal Program Names: Health Center Program Cluster Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the HOmeless, and Public Housing Primary Care) Grants for New and Expanded Services under the Health Center Program 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. Condition The Center did not always have the proper slide fee documentation readily available to ensure the proper slide fee discount was applied based on approved policies or the discount was calculated incorrectly. Cause The Center did not have adequate internal controls in place to effectively ensure that all sliding fee discounts were properly calculated based on approved documentation. Effect or Potential Effect The Center did not comply with the appropriate rules and regulations as per the Uniform Guidance. Questioned Costs None Context A test of 40 sliding fee discount transactions was performed and resulted in 20 instances where the Center was unable to provide approved documentation which lead to the sliding fee discount being calculated incorrectly. Our sample was a statistically valid sample. Identification of Repeat Finding This finding is a repeat finding (see prior year finding number: 2024.003) Recommendation The Center should establish a system of internal controls to ensure that all sliding fee discounts are properly calculated and supported based on family size and income. Views of Responsible Officials and Planned Corrective Actions Management agrees with the audit finding and will strengthen internal controls and accountability to correct the deficiency. Management has prepared a Corrective Action Plan that outlines the additional controls implemented.

Corrective Action Plan

Finding 2025.002 - Special Tests and Provisions - Sliding Fee Scale Documentation Recommendation The Center should establish a system of internal controls to ensure that all sliding fee discounts are properly calculated and supported based on family size and income. Action Taken This was also a finding in the 2023 Audit and again in 2024. In response to the audit finding, I worked directly with the Director of Clinical Operations and the Patient Service Representative Manager to conduct a comprehensive review of the health center's existing sliding fee scale policy to ensure alignment with federal guidelines and best practices, including clarification of documentation requirements, acceptable forms of income verification, and the definition of family size. We developed and implemented a step-by-step standard operating procedure (SOP) for Patient Service Representative (PSR) staff to consistently assess and apply sliding fee discounts. The SOP includes clear instructions for verifying documentation, calculating discount eligibility, and recording determinations in the patient's record. The Clinical Operations Director's management team will conduct quarterly spot audits of a sample of sliding fee files to verify correct application and documentation. The managers will report the findings to leadership, provide corrective follow-up, and provide any needed training for PSR personnel on the updated policy and procedures. I reported all identified and assessed changes to the health center's board of directors or its audit committee for review and oversight. The board verified that appropriate corrective action was being taken regarding internal controls. Waikiki Health is also considering engaging an outside firm to assist with streamlining the sliding fee scale process and strengthening related internal controls.

Categories

Special Tests & Provisions Subrecipient Monitoring Eligibility HUD Housing Programs Material Weakness Internal Control / Segregation of Duties

Other Findings in this Audit

  • 1236206 2025-001
    Material Weakness Repeat
  • 1236207 2025-001
    Material Weakness Repeat
  • 1236208 2025-002
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
93.224 HEALTH CENTER PROGRAM $1.68M
93.918 GRANTS TO PROVIDE OUTPATIENT EARLY INTERVENTION SERVICES WITH RESPECT TO HIV DISEASE $330,936
93.932 NATIVE HAWAIIAN HEALTH CARE SYSTEMS $175,038
93.527 GRANTS FOR NEW AND EXPANDED SERVICES UNDER THE HEALTH CENTER PROGRAM $35,136
93.493 CONGRESSIONAL DIRECTIVES $23,400