Finding 45452 (2022-001)

Significant Deficiency Repeat Finding
Requirement
N
Questioned Costs
-
Year
2022
Accepted
2022-12-15
Audit: 50978
Auditor: Cohnreznick LLP

AI Summary

  • Core Issue: The Center lacked proper documentation for sliding fee discounts, leading to incorrect calculations for eligible patients.
  • Impacted Requirements: This finding violates the Uniform Guidance, which mandates accurate sliding fee policies based on family size and income.
  • Recommended Follow-Up: Implement stronger internal controls to ensure all sliding fee discounts are calculated correctly and consistently.

Finding Text

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 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 Federal Assistance Listing Numbers: 93.224 and 93.527 Criteria In accordance with the Uniform Guidance, the Center must prepare and apply a sliding fee discount policy and schedule so that the amounts owed for health center services by eligible patients are adjusted (discounted) based on a patient's poverty level, which is determined by the patient's family size and income. 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 40 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 Yes 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 November 30, 2022 United States Department of Health and Human Services Generations Family Health Center, Inc. respectfully submits the following corrective action plan for the year ended June 30, 2022. CohnReznick LLP 350 Church Street Hartford, CT 06103 Audit Period: June 30, 2022 The findings from the June 30, 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: Three new internal controls will be implemented immediately: 1. Upon adding a new charge to the system, the Director of Patient Revenue will post the charge into a test patient account to confirm that the standard fee and slide rates match those entered on the fee schedule. Set up will be verified by the Billing Manager. 2. At the annual review and/or revision of the Agency's fee schedule, the Billing Manager will assist the Director of Patient Revenue in reviewing every charge on the updated/approved year's fee schedule to confirm the rates and slide assignment match the Fee Schedule. 3. A quarterly audit of underinsured and self-pay patients will occur to review that adjustments are correct per agency policy for slide documentation. If the Cognizant or Oversight Agency for Audit has questions regarding this plan, please contact me at dsavie@genhealth.org or 860-456-6271. Sincerely, Debra Daviau Savoie, MBA Chief Financial Officer

Categories

HUD Housing Programs Internal Control / Segregation of Duties

Other Findings in this Audit

  • 45453 2022-001
    Significant Deficiency Repeat
  • 45454 2022-001
    Significant Deficiency Repeat
  • 45455 2022-001
    Significant Deficiency Repeat
  • 621894 2022-001
    Significant Deficiency Repeat
  • 621895 2022-001
    Significant Deficiency Repeat
  • 621896 2022-001
    Significant Deficiency Repeat
  • 621897 2022-001
    Significant Deficiency Repeat

Programs in Audit

ALN Program Name Expenditures
93.527 Affordable Care Act (aca) Grants for New and Expanded Services Under the Health Center Program $3.29M
93.526 Affordable Care Act (aca) Grants for Capital Development in Health Centers $556,256
93.918 Grants to Provide Outpatient Early Intervention Services with Respect to Hiv Disease $326,577
93.268 Immunization Cooperative Agreements $192,400
93.224 Consolidated Health Centers (community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) $137,981
93.994 Maternal and Child Health Services Block Grant to the States $32,192
93.153 Coordinated Services and Access to Research for Women, Infants, Children, and Youth $30,865
93.461 Covid-19 Testing for the Uninsured $22,419