Finding 4260 (2022-002)

Significant Deficiency Repeat Finding

Requirement

Questioned Costs

Year

2022

Accepted

2023-12-13

Audit: 6569

Organization: Asian and Pacific Islander Wellness Center, Inc. D/b/a San Francisco Community Health Center (CA)

Auditor: Chw LLP

AI Summary

Core Issue: The Center is not correctly determining patient discounts based on their ability to pay, leading to potential over- or under-discounting.
Impacted Requirements: Compliance with federal grant provisions regarding sliding fee schedules is not being met, as identified in previous audits.
Recommended Follow-Up: Provide training for staff on sliding fee program requirements and implement additional controls to prevent recurrence.

Finding Text

2022-002 Sliding Fee Discount Determination CFDA Number: 93.224 Program: Community Health Center Cluster Compliance Requirement: (N) Special Tests and Provisions Criteria: Federal grant compliance provisions require that the Center correctly identify a patient's ability to pay and that the rates for services be adjusted accordingly based on the sliding fee schedule. The Center is required to follow its sliding fee policy when providing discounts to eligible patients. Finding/ Condition: In our sample of tested items, patient information was inadequate to determine the proper sliding fee discount or patients were given incorrect discounts based on information provided. Questioned Cost: None. Effect: Lack of strict enforcement of the policy of sliding fee eligibility determination and compliance may have resulted in the Center providing discounted services greater to or less than the appropriate amounts to beneficiaries. Cause: In the prior year the Center became aware of deficiencies in the sliding fee program through the annual external audit. By the time the deficiencies were reported there was not enough time to implement corrective actions for the current year. Thus, the same deficiencies were found in consecutive years. Repeat Finding: This is a repeat finding. Please see finding 2021-002. Recommendation: Training should be provided to employees on the sliding fee program requirements. Views of Responsible Officials and Corrective Action Plan: The Center agrees with the finding and will implement additional controls to ensure that this does not recur. Please refer to the corrective action plan on page 35.

Corrective Action Plan

2022-001 Internal Control Over Financial Close Process Name of Contact Person: Chief Financial Officer: Amber Curley Corrective Action: The Center agrees with this finding and recommendations. The Center went through a change in CFO leadership throughout this fiscal year and our full-time permanent CFO started in January 2022, who then immediately expanded the Center’s finance department and implemented corrective procedures and greatly improved accounting processes and accounting operations, including all balance sheet accounts being reviewed and reconciled in a timely manner. In order to ensure we are fully compliant, two new positions were created and filled – a 1.0 FTE Controller hired in July 2022 and a 1.0 FTE Staff Accountant hired in January 2023. Additionally, our CFO overhauled our financial policies and procedures manual which was approved by the Center’s Board of Directors in July 2022. These policies and procedures were also reviewed by our HRSA consultants during our three-day operational site visit which took place in July 2022. Specific process improvements were made and included more specific segregation of duties, enhanced communication across all departments to address program items around budgetary and resource planning, transactional accuracy, and transparency. Moreover, the five-member finance department is working collaboratively with program management to advise and support the finance department on continued process improvements and maintaining open communication with program staff for effective feedback on program monitoring systems essential to strengthening internal control over financial close and reporting process. Proposed Completion Date: June 30, 2023

Other Findings in this Audit

4261 2022-003

Significant Deficiency
4262 2022-004

Significant Deficiency
580702 2022-002

Significant Deficiency Repeat
580703 2022-003

Significant Deficiency
580704 2022-004

Significant Deficiency

Programs in Audit

ALN	Program Name	Expenditures
93.834	Capacity Building Assistance (cba) for High-Impact Hiv Prevention	$680,646
93.914	Hiv Emergency Relief Project Grants	$358,530
93.243	Substance Abuse and Mental Health Services_projects of Regional and National Significance	$214,305
93.918	Grants to Provide Outpatient Early Intervention Services with Respect to Hiv Disease	$140,666
93.224	Consolidated Health Centers (community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care)	$2,366