FAC Explorer

Finding 43187 (2022-002)

Significant Deficiency Repeat Finding
Requirement
N
Questioned Costs
-
Year
2022
Accepted
2023-08-10
Audit: 48323
Organization: La Clinica Tepeyac (CO)
Auditor: Cliftonlarsonallen LLP

AI Summary

  • Core Issue: There was a significant deficiency in internal controls over the application of sliding fee discounts, leading to incorrect discounts being applied to patients.
  • Impacted Requirements: Compliance with Title 42 regulations requiring health centers to maintain accurate fee schedules and discount applications based on patients' ability to pay.
  • Recommended Follow-Up: Implement a peer review process for sliding fee applications, ensure all applications are retained, and provide training for staff by September 30, 2023, with a new patient application process by October 31, 2023.

Finding Text

2022 ? 002 Special Tests: Application of Sliding Fee Discount Federal Agency: U.S. Department of Health and Human Services Federal Program: Consolidated Health Centers Grant AL Number: 93.224 & 93.527 Award Period: 1/1/22 - 12/31/22 Type of Finding: Significant deficiency in Internal Control over Compliance and Compliance Criteria or Specific Requirement Per Title 42 Chapter 1 Subchapter D Section 51c303(f), ?Health centers must have a schedule of fees or payments for the provision of their health services consistent with locally prevailing rates or charges designed to cover their reasonable costs of operation. They are also required to have a corresponding schedule of discounts applied and adjusted on the basis of the patient?s ability to pay.? Section III ? Findings and Questioned Costs ? Major Federal Programs (Continued) 2022 ? 002 Special Tests: Application of Sliding Fee Discount (Continued) Condition and Context During our testing of forty sliding fee discounts for health center patients qualifying for reduced charge visits, we identified one visit that received the incorrect sliding fee discount. We also identified one visit where the Organization was not able to locate the sliding fee discount application. Effect Potential that a patient would not receive the appropriate sliding fee discount. Questioned Costs None identified. Cause Clerical error in which the incorrect discount was applied due to lack of an oversight process in place. Recommendation We recommend the Organization to review internal controls in regards to the determination, recording, and monitoring of the sliding fee process to ensure that appropriate sliding fee rates/categories are utilized for each sliding fee encounter. We also recommend the Organization put a process in place to make sure all applications are retained. Views of Responsible Officials The Organization will implement the following peer review process: ? A peer review is required to determine the appropriate sliding fee calculation was made based on family size and income of the applicant. ? A reference and training guide will be created by the Organization for front desk staff and enrollment specialists to utilize by September 30, 2023. ? Each sliding fee application will be reviewed by a peer and signed off by both the submitter and the peer reviewer. A verification checklist will be utilized to ensure the sliding fee application is accurate and complete. ? The finance department will receive a list of all new sliding fee applications from the previous month and pull a sample of twenty applications to review for accuracy and to confirm the peer review occurred. ? The Organization will implement a process where the patients will complete the sliding fee application prior to seeing the provider. The process is expected to be implemented by October 31, 2023.

Corrective Action Plan

2022-002 Consolidated Health Centers Grant ? Assistance Listing No. 93.224 & 93.527 Recommendation: Our auditors recommended the Organization to review internal controls in regards to the determination, recording, and monitoring of the sliding fee process to ensure that appropriate sliding fee rates/categories are utilized for each sliding fee encounter. The auditors also recommended the Organization put a process in place to make sure all applications are retained. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Organization will implement the following peer review process: ? A peer review is required to determine the appropriate sliding fee calculation was made based on family size and income of the applicant. ? A reference and training guide will be created by the Organization for front desk staff and enrollment specialists to utilize by September 30, 2023. ? Each sliding fee application will be reviewed by a peer and signed off by both the submitter and the peer reviewer. A verification checklist will be utilized to ensure the sliding fee application is accurate and complete. ? The finance department will receive a list of all new sliding fee applications from the previous month and pull a sample of twenty applications to review for accuracy and to confirm the peer review occurred. ? The Organization will implement a process where the patients will complete the sliding fee application prior to seeing the provider. The process is expected to be implemented by October 31, 2023. If the U.S. Department of Health and Human Services has questions regarding this plan, please call Jim Garcia, CEO, at 720-274-2941.

Categories

Internal Control / Segregation of Duties Subrecipient Monitoring Significant Deficiency Special Tests & Provisions

Other Findings in this Audit

  • 43186 2022-001
    Significant Deficiency
  • 43188 2022-001
    Significant Deficiency
  • 43189 2022-002
    Significant Deficiency Repeat
  • 43190 2022-001
    Significant Deficiency
  • 43191 2022-002
    Significant Deficiency Repeat
  • 43192 2022-001
    Significant Deficiency
  • 43193 2022-002
    Significant Deficiency Repeat
  • 43194 2022-001
    Significant Deficiency
  • 619628 2022-001
    Significant Deficiency
  • 619629 2022-002
    Significant Deficiency Repeat
  • 619630 2022-001
    Significant Deficiency
  • 619631 2022-002
    Significant Deficiency Repeat
  • 619632 2022-001
    Significant Deficiency
  • 619633 2022-002
    Significant Deficiency Repeat
  • 619634 2022-001
    Significant Deficiency
  • 619635 2022-002
    Significant Deficiency Repeat
  • 619636 2022-001
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
93.493 Community Project Funding/congressionally Directed Spending - Construction $2.00M
93.224 American Rescue Plan Act Funding for Health Centers $657,771
93.224 Consolidated Health Centers (community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) $633,008
93.526 Health Center Infrastructure Support $316,882
93.185 Immunization Research, Demonstration, Public Information and Education_training and Clinical Skills Improvement Projects $182,432
93.914 Hiv Emergency Relief Project Grants $153,563
93.898 Cancer Prevention and Control Programs for State, Territorial and Tribal Organizations $57,775
93.527 Fy 2023 Expanding Covid-19 Vaccination $26,088
93.000 Miscellaneous Administrative Expenses $19,460
93.800 Organized Approaches to Increase Colorectal Cancer Screening $14,389
93.991 Preventive Health and Health Services Block Grant $7,194
93.527 Consolidated Health Centers (community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) $0