Finding 25634 (2022-001)

Significant Deficiency
Requirement
N
Questioned Costs
-
Year
2022
Accepted
2022-11-18
Audit: 20119
Organization: Staywell Healthcare, Inc. (CT)
Auditor: Cohnreznick LLP

AI Summary

  • Core Issue: The Center failed to maintain proper documentation for patients' income and family size related to the sliding fee discount policy.
  • Impacted Requirements: This non-compliance with the Uniform Guidance affects the Center's ability to apply discounts based on patients' poverty levels.
  • Recommended Follow-Up: Implement stronger internal controls to ensure all sliding fee discounts are adequately documented and compliant with policy.

Finding Text

Federal Award Findings and Questioned Costs 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), 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 documentation on file to support the patient's income and family size. Context A test of 25 sliding fee discount transactions was performed and resulted in one instance where the Center was unable to provide approved documentation. 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 sliding fee discount information is on file and illustrates the appropriate discount based on the Center's sliding fee discount policy. Effect The Center did not comply with the appropriate rules and regulations as per the Uniform Guidance. Identification of Repeat Finding No. Recommendation The Center should establish a system of internal controls to ensure that all sliding fee discounts are properly supported.

Corrective Action Plan

CORRECTIVE ACTION PLAN November 14, 2022 United States Department of Health and Human Services Staywell Health Care, Inc. respectfully submits the following corrective action plan for the year ended June 30, 2022. CohnReznick LLP 350 Church Street Hartford, CT 06103 Audit Period: June 30, 2022 The findings from the June 30, 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 2022.001 - Sliding Fee Scale Discount Recommendation The Center should ensure that internal controls are in place to ensure that all sliding fee discounts are properly supported. Action Taken Effective November 1, 2022 all the Practice Managers (PM) and Director of Practice Management have been and will continue to review and monitor the sliding fee discount (SFD) on a daily basis on all slides for internal control. StayWell's newly implemented Patent Intake solution, 'Phreesia' has a dashboard in which this tool is being utilized effective November 1st, 2022 to monitor internal controls at the front desk operations with regard to accuracy of registration, patient demographic, insurance verification and most importantly the application of the Sliding Fee Discount Program and ensuring there is proper documentation to support (POI). Monthly random audits on the sliding fee discount program will continue to be performed by the PM's and the Director of Practice Management. Director of Practice Management will also continue to perform SFD program compliance education to all Patients Service Associates (PSA) and all Practice Managers (PM) on a as needs basis. If the Cognizant or Oversight Agency for Audit has questions regarding this plan, please call: Lule Tracey, CFO at (203) 756-8021 ext. 3015. Lule Tracy, Chief Financial Officer ltracey@staywellhealth.org

Categories

HUD Housing Programs Internal Control / Segregation of Duties

Other Findings in this Audit

  • 25635 2022-001
    Significant Deficiency
  • 25636 2022-001
    Significant Deficiency
  • 602076 2022-001
    Significant Deficiency
  • 602077 2022-001
    Significant Deficiency
  • 602078 2022-001
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
93.527 Affordable Care Act (aca) Grants for New and Expanded Services Under the Health Center Program $3.33M
93.224 Consolidated Health Centers (community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) $1.72M
93.914 Hiv Emergency Relief Project Grants $716,518
93.918 Grants to Provide Outpatient Early Intervention Services with Respect to Hiv Disease $402,315
93.498 Provider Relief Fund (prf) and American Rescue Plan (arp) Rural Distribution $345,265
93.391 Activities to Support State, Tribal, Local and Territorial (stlt) Health Department Response to Public Health Or Healthcare Crises $128,933
93.137 Community Programs to Improve Minority Health Grant Program $109,516
93.243 Substance Abuse and Mental Health Services_projects of Regional and National Significance $88,016
14.231 Emergency Solutions Grant Program $77,414
93.153 Coordinated Services and Access to Research for Women, Infants, Children, and Youth $43,006
93.940 Hiv Prevention Activities_health Department Based $36,810
93.268 Immunization Cooperative Agreements $21,454
93.590 Community-Based Child Abuse Prevention Grants $10,475
21.027 Coronavirus State and Local Fiscal Recovery Funds $1,937