Finding 20234 (2022-001)

Significant Deficiency Repeat Finding
Requirement
N
Questioned Costs
-
Year
2022
Accepted
2023-05-30
Audit: 19676
Organization: Community Health Services, Inc. (CT)
Auditor: Cohnreznick LLP

AI Summary

  • Core Issue: The Center failed to consistently document sliding fee discounts, leading to incorrect charges for patients based on their income levels.
  • Impacted Requirements: Compliance with the Uniform Guidance for sliding fee discount policies was not met, affecting eligible patients' access to discounted services.
  • Recommended Follow-Up: Implement stronger internal controls to ensure accurate application of sliding fee discounts and prevent future discrepancies.

Finding Text

Finding 2022.001: Sliding Fee Scale Documentation Grantor: 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), COVID-19 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, COVID-19 Grants for New and Expanded Services Under the Health Center Program Federal Assistance Listing Numbers: 93.224 and 93.527 Criteria In accordance with the Uniform Guidance, the Center must prepare and apply a sliding fee discount policy and schedule so that the amounts owed for health center services by eligible patients are adjusted (discounted) based on a patient's poverty level, which is determined by the patient's income and family size. Condition The Center did not always have the proper sliding fee documentation entered into the system for the patients, therefore, was not able to apply the sliding fee discount based on income levels. Context A test of 40 sliding fee discount transactions was performed and resulted in two instances where a patient was charged the incorrect sliding fee discount. Our sample was a statistically valid sample. Questioned Costs None. Cause The Center did not have adequate internal controls in place to effectively ensure that the proper slide fee discount is applied. Effect The Center did not comply with the appropriate rules and regulations as per the Uniform Guidance. Identification of Repeat Finding Yes ? 2021.001. Recommendation The Center should implement controls to ensure proper sliding fee discounts are provided. Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding.

Corrective Action Plan

CORRECTIVE ACTION PLAN May 22, 2023 United States Department of Health and Human Services Community Health Services, Inc. respectfully submits the following corrective action plan for the year ended December 31, 2022. CohnReznick LLP 350 Church Street Hartford, CT 06103 Audit Period: December 31, 2022 The findings from the December 31, 2022 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FEDERAL AWARDS FINDINGS AND QUESTIONED COSTS SIGNIFICANT DEFICIENCY 2021.001 ? Sliding Fee Scale Discount Recommendation The Center should implement controls to ensure proper slide fee discounts are provided. Action Taken The Center implemented internal controls to mitigate the risk of missing sliding fee discount documentation. The creation of this control consisted of designing a report that would identify all sliding fee discount applicants for the specified timeframe, as well as identify whether supporting documentation had been scanned into the patient?s electronic health record. As a result of the repeated finding, the Center added an additional layer of review. The Director of Development, Grants and Outreach reviews all slide applications before they are scanned and entered into the electronic health record and applied to the patient?s account. The Center will continue monthly internal auditing procedures where an Eligibility Specialist haphazardly selects slide applications from the previous month to ensure compliance. If the Cognizant or Oversight Agency for Audit has questions regarding this plan, please call: Dianna Kulmacz, CFO at (860) 808-8765. Sincerely yours, Dianna Kulmacz Chief Financial Officer

Categories

HUD Housing Programs Internal Control / Segregation of Duties

Other Findings in this Audit

  • 20235 2022-001
    Significant Deficiency Repeat
  • 20236 2022-001
    Significant Deficiency Repeat
  • 20237 2022-001
    Significant Deficiency Repeat
  • 20238 2022-001
    Significant Deficiency Repeat
  • 20239 2022-001
    Significant Deficiency Repeat
  • 596676 2022-001
    Significant Deficiency Repeat
  • 596677 2022-001
    Significant Deficiency Repeat
  • 596678 2022-001
    Significant Deficiency Repeat
  • 596679 2022-001
    Significant Deficiency Repeat
  • 596680 2022-001
    Significant Deficiency Repeat
  • 596681 2022-001
    Significant Deficiency Repeat

Programs in Audit

ALN Program Name Expenditures
93.268 Immunization Cooperative Agreements $546,757
93.918 Grants to Provide Outpatient Early Intervention Services with Respect to Hiv Disease $319,168
93.526 Affordable Care Act (aca) Grants for Capital Development in Health Centers $285,092
93.914 Hiv Emergency Relief Project Grants $170,133
93.153 Coordinated Services and Access to Research for Women, Infants, Children, and Youth $147,137
93.926 Healthy Start Initiative $74,045
93.224 Consolidated Health Centers (community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) $37,208
93.044 Special Programs for the Aging_title Iii, Part B_grants for Supportive Services and Senior Centers $19,050
93.318 Protecting and Improving Health Globally: Building and Strengthening Public Health Impact, Systems, Capacity and Security $13,712
96.001 Social Security_disability Insurance $13,420
93.527 Affordable Care Act (aca) Grants for New and Expanded Services Under the Health Center Program $9,075
93.498 Covid-19 - Provider Relief Fund and American Rescue Plan (arp) Rural Distribution $5,920
93.461 Covid-19 - Hrsa Covid-19 Claims Reimbursement for the Uninsured Program and the Covid-19 Coverage Assistance Fund $5,488