Finding 28620 (2022-001)

Significant Deficiency
Requirement
N
Questioned Costs
-
Year
2022
Accepted
2023-08-10

AI Summary

  • Core Issue: The Center lacked proper documentation for sliding fee discounts, leading to incorrect calculations for some patients.
  • Impacted Requirements: Compliance with federal guidelines for determining patient eligibility based on income and family size was not met.
  • Recommended Follow-Up: Implement stronger internal controls to ensure accurate calculation of sliding fee discounts and monitor compliance regularly.

Finding Text

Section III - Federal Awards 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 Center, 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. Federal Assistance Listing Numbers: 93.224 and 93.527 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. Context A test of 25 discount transactions was performed and resulted in two instances of sliding fee discounts not being properly calculated based on the respective patient family size and income. 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 all sliding fee discounts were properly calculated based on approved documentation. 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 calculated based on family size and income. Views of Responsible Officials Management agrees with the audit finding and will strengthen internal controls and accountability to correct the deficiency.

Corrective Action Plan

CORRECTIVE ACTION PLAN July 27, 2023 United Stated Department of Health and Human Services Northern Oswego County Health Services, Inc. d/b/a ConnextCare respectfully submits the following corrective action plan for the year ended December 31, 2022. Cohn Reznick 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 2022-001 - Sliding Fee Scale Discount Recommendation The Center should establish a system of internal controls to ensure that all sliding fee discounts are properly calculated based on family size and income. Action Taken ConnextCare as established the following system of internal controls, effective immediately: 1) Monthly internal audits of new patient records being entered into our practice management system. This review will ensure the proper character (U) is entered into the Sliding Fee Scale tab. 2) Review of accounts when new Income Verification forms are received from the patients to ensure that reported income aligns with the practice management system. In addition, perform monthly audits of 25 active Sliding Fee Scale patients for proper Slide percentage and calculation. 3) Additional training provided to all Patient Access Representatives, Medical and Dental Billing Staff on proper calculation of a self-pay eligible sliding fee scale patient. If the Cognizant or Oversight Agency for Audit has questions regarding this plan, please call: Tracy Wimmer, CFO at (315) 298-6569, ext. 2020. Tracy Wimmer Sr. VP/Chief Financial Officer

Categories

Subrecipient Monitoring Eligibility HUD Housing Programs Internal Control / Segregation of Duties

Other Findings in this Audit

  • 28621 2022-001
    Significant Deficiency
  • 28622 2022-001
    Significant Deficiency
  • 605062 2022-001
    Significant Deficiency
  • 605063 2022-001
    Significant Deficiency
  • 605064 2022-001
    Significant Deficiency

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) $2.74M
93.527 Affordable Care Act (aca) Grants for New and Expanded Services Under the Health Center Program $2.43M
93.526 Affordable Care Act (aca) Grants for Capital Development in Health Centers $781,992
21.027 Coronavirus State and Local Fiscal Recovery Funds $400,000
93.354 Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response $360,626
93.498 Provider Relief Fund and American Rescue Plan (arp) Rural Distribution $248,788
93.994 Maternal and Child Health Services Block Grant to the States $78,687
93.525 State Planning and Establishment Grants for the Affordable Care Act (aca)?s Exchanges $8,192
93.778 Medical Assistance Program $8,192
93.767 Children's Health Insurance Program $8,192
93.912 Rural Health Care Services Outreach, Rural Health Network Development and Small Health Care Provider Quality Improvement $7,350