Finding 401079 (2022-004)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
$1
Year
2022
Accepted
2024-06-18
Audit: 309100
Organization: Promise Healthcare Nfp (IL)

AI Summary

  • Core Issue: The Organization incorrectly assessed the sliding fee discount for patient services, impacting compliance with federal requirements.
  • Impacted Requirements: Health centers must apply a sliding fee discount based on patients' ability to pay, as mandated by federal regulations.
  • Recommended Follow-Up: Increase self-reviews of patient encounters, expand sample sizes, and provide additional training for front desk staff on patient information collection.

Finding Text

2022-003 – Special Tests and Provisions Federal agency: U.S. Department of Health and Human Services Federal program title: Health Centers Cluster Assistance Listing Number: 93.224/93.527 Pass-Through Agency: n/a Pass-Through Number(s): n/a Award Period: 6/1/21-5/31/22 & 6/1/22-5/31/23 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or specific requirement: Health centers must prepare and apply a sliding fee discount schedule so that the amounts owed for health center services by eligible patients are adjusted (discounted) based on the patient’s ability to pay. (42 USC 254(k)(3)(E), (F), and (G); 42 CFR sections 51c.303(e), (f), and (g); and 42 CFR sections 56.303(e), (f), and (g)). Condition: The Organization assessed an incorrect sliding fee discount. Questioned costs: None. Context: The Organization assessed one of forty patient encounters selected for testing, the incorrect sliding fee discount. Cause: Unknown Effect: Patients are not charged according to the Organization's sliding fee scale and their ability to pay. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2021-008. Recommendation: Management should consider increasing the frequency of its self-reviews of patient encounters or expanding its sample sizes in addition to providing additional training for front desk staff regarding the collection and verification of patient information for each patient. Views of responsible officials: There is no disagreement with the audit finding.

Corrective Action Plan

Procurement – Assistance Listing No. 93.224/93.527 Recommendation: We recommend that Promise Healthcare revise its procurement policy to be consistent with the requirements of the Uniform Guidance and follow the stated procedures. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: 1. Review Current Procurement Policy: in progress a. Conduct a comprehensive review of Promise Healthcare’s existing procurement policy. b. Identify and revise and discrepancies or non-compliance with the requirements of the Uniform Guidance. c. Integrate industry best practices into revised policy to enhance compliance and efficiency 2. Training and Education: to start a. Provide training sessions for staff authorized to purchase along with relevant personnel on the revised procurement policy and procedures and raise awareness of the requirements of the Uniform Guidance and implications of non-compliance. b. Establish training on documentation standards for procurement activities including requisitions, solicitations, evaluations and contract awards. c. Establish training and procedure for retention of procurement-related documentation 3. Internal Controls and oversight: to start a. Implement mechanisms for monitoring and oversight to ensure compliance with the procurement policy. b. Conduct periodic internal audits to assess adherence to procurement procedures and identify areas for improvement or corrective action

Categories

Questioned Costs Special Tests & Provisions Significant Deficiency Internal Control / Segregation of Duties

Other Findings in this Audit

  • 401076 2022-003
    Significant Deficiency Repeat
  • 401077 2022-003
    Significant Deficiency Repeat
  • 401078 2022-003
    Significant Deficiency Repeat
  • 401080 2022-004
    Material Weakness Repeat
  • 401081 2022-004
    Material Weakness Repeat
  • 401082 2022-006
    Significant Deficiency Repeat
  • 401083 2022-006
    Significant Deficiency Repeat
  • 401084 2022-006
    Significant Deficiency Repeat
  • 401085 2022-005
    Material Weakness Repeat
  • 401086 2022-005
    Material Weakness Repeat
  • 401087 2022-005
    Material Weakness Repeat
  • 977518 2022-003
    Significant Deficiency Repeat
  • 977519 2022-003
    Significant Deficiency Repeat
  • 977520 2022-003
    Significant Deficiency Repeat
  • 977521 2022-004
    Material Weakness Repeat
  • 977522 2022-004
    Material Weakness Repeat
  • 977523 2022-004
    Material Weakness Repeat
  • 977524 2022-006
    Significant Deficiency Repeat
  • 977525 2022-006
    Significant Deficiency Repeat
  • 977526 2022-006
    Significant Deficiency Repeat
  • 977527 2022-005
    Material Weakness Repeat
  • 977528 2022-005
    Material Weakness Repeat
  • 977529 2022-005
    Material Weakness Repeat

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) $1.94M
93.526 Affordable Care Act (aca) Grants for Capital Development in Health Centers $158,002
93.994 Maternal and Child Health Services Block Grant to the States $110,358
93.354 Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response $89,452
93.527 Affordable Care Act (aca) Grants for New and Expanded Services Under the Health Center Program $75,110
93.332 Cooperative Agreement to Support Navigators in Federally-Facilitated and State Partnership Marketplaces $56,929
93.268 Immunization Cooperative Agreements $55,681
93.323 Epidemiology and Laboratory Capacity for Infectious Diseases (elc) $33,008
93.498 Provider Relief Fund $20,617
93.461 Covid-19 Testing for the Uninsured $10,782