Finding 395635 (2023-001)

Significant Deficiency Repeat Finding

Requirement

Questioned Costs

Year

2023

Accepted

2024-05-01

Audit: 305248

Organization: Community Health Services, Inc. (CT)

Auditor: Cohnreznick LLP

AI Summary

Core Issue: The Center failed to accurately calculate sliding fee discounts based on patient family size and income.
Impacted Requirements: This non-compliance with federal guidelines affects the Center's adherence to the sliding fee scale regulations.
Recommended Follow-up: Implement stronger internal controls to ensure accurate calculations and maintain proper documentation for all sliding fee discounts.

Finding Text

Finding 2023-001: Special Tests and Provisions 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, COVID-19 Grant 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 slide fee discounts issued to patients in accordance with the Center's sliding fee scale. Condition The Center did not always calculate the proper slide fee discount based on the respective patient family size and income or have adequate documentation on file to support the proper slide fee discount. Context A test of 40 sliding fee discount transactions was performed and resulted in an instance of a sliding fee discount 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 the proper slide fee discount was 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 Yes - 2022.001. Recommendation The Center should implement controls to ensure that all sliding fee discounts are properly calculated 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.

Corrective Action Plan

Community Health Services, Inc. respectfully submits the following corrective action plan for the year ended December 31, 2023. CohnReznick LLP 350 Church Street Hartford, CT 06103 Audit Period: December 31, 2023 The findings from the December 31, 2023 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 Section Ill- Federal Award Findings and Questioned Costs 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 and COVID-19 Grants for New and Expanded Services under the Health Center Program Federal Assistance Listing Numbers: 93.224 and 93.527 Item 2023-00.1 - Special Tests 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. Repeat Finding Yes 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. The Director of Development, Grants and Outreach or the Director of Finance and Grants Administration 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. As a result of the repeated finding, the Center created an excel template that will accurately calculate and feed the slide result in effort to minimize manual calculation errors. If the Cognizant or Oversight Agency for Audit has questions regarding this plan, please call: Dianna Kulmacz, CFO at (860) 808-8765.

Other Findings in this Audit

395636 2023-001

Significant Deficiency Repeat
395637 2023-001

Significant Deficiency Repeat
395638 2023-001

Significant Deficiency Repeat
395639 2023-001

Significant Deficiency Repeat
972077 2023-001

Significant Deficiency Repeat
972078 2023-001

Significant Deficiency Repeat
972079 2023-001

Significant Deficiency Repeat
972080 2023-001

Significant Deficiency Repeat
972081 2023-001

Significant Deficiency Repeat

Programs in Audit

ALN	Program Name	Expenditures
93.268	Immunization Cooperative Agreements	$612,707
93.918	Grants to Provide Outpatient Early Intervention Services with Respect to Hiv Disease	$310,673
93.527	Affordable Care Act (aca) Grants for New and Expanded Services Under the Health Center Program	$223,854
93.224	Consolidated Health Centers (community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care)	$210,000
93.914	Hiv Emergency Relief Project Grants	$174,972
93.153	Coordinated Services and Access to Research for Women, Infants, Children, and Youth	$149,905
93.526	Affordable Care Act (aca) Grants for Capital Development in Health Centers	$120,800
93.498	Provider Relief Fund and American Rescue Plan (arp) Rural Distribution	$93,329
93.926	Healthy Start Initiative	$72,542
93.044	Special Programs for the Aging_title Iii, Part B_grants for Supportive Services and Senior Centers	$30,450
96.001	Social Security_disability Insurance	$11,480
21.027	Coronavirus State and Local Fiscal Recovery Funds	$2,091