Finding 47917 (2022-002)

Significant Deficiency Repeat Finding
Requirement
N
Questioned Costs
-
Year
2022
Accepted
2023-04-18

AI Summary

  • Core Issue: The Center failed to apply the sliding fee discount correctly based on patients' income and family size.
  • Impacted Requirements: This non-compliance violates the Uniform Guidance regarding health center service fees.
  • Recommended Follow-Up: Implement stronger internal controls to ensure accurate application of sliding fee discounts.

Finding Text

U.S. Department of Health and Human Services, COVID-19 - Health Center Program Cluster (Assistance Listing Number 93.224/93.527) Item 2022-002 ? Special Tests and Provisions 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 appropriately apply the sliding fee discount based on income levels and family size. Context A test of 40 discount transactions was performed and resulted in three 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. Cause The Center did not have adequate internal controls in place to effectively ensure that patients receive the correct sliding fee discount. Effect The Center did not comply with the appropriate rules and regulations as per the Uniform Guidance. Questioned Costs None Identification of Repeat Finding Yes ? 2021-004 Recommendation The Center should ensure that internal controls are in place to effectively ensure that patients receive the correct sliding fee discount. View of Responsible Officials Management and the Board of Directors agree with the finding.

Corrective Action Plan

April 4, 2023, Betty Jean Kerr- People's Health Centers respectfully submits the following corrective action plan for the year ended May 31, 2022. CohnReznick, LLP 350 Church Street Hartford, CT 06103 Audit Period: May 31, 2022 Section II- Financial Statement Findings: Item 2022-001- Financial Reporting Recommendation We recommend that the Center ensure that the monthly financial statement close process is being performed in a timely and accurate manner. Action Taken: 1. Review Monthly Closing checklist to it is complete and save as Master Monthly Closing Listing on Shared Drive and is shared electronically and by paper to all accounting team members. The Closing listing will address all the activities before closing accounting records for the month. The focus should be: - ensure whether maintain a "Manual GL Entry List" to list down those commonly recurring GL entries together with preparer and reviewer. - determining what supporting files are required, and responsibility of related teams (billing, management, etc). - determining suggested completion day to ensure the completeness of GL entry during closing. 2. The closing checklist reviewed will be shared by Finance Controller and/or delegated role in a timely manner no later than 7 days before month end. Responsible Party: Director of Finance Completion Date: June 30,2022. Prior year audit FY2021 (06/01/2020 - 05/31/2021) was completed late by BKD, in May of 2022, the corrective action plan was implemented in June of 2022. Therefore, this finding was required for in FY2022 (06/01/2021- 05/31/2022} as well. Section Ill- Federal Award Findings and Questioned Costs U.S. Department of Health and Human Services, COVID-19 - Health Center Program Cluster (Assistance Listing Number 93.224/93.527) Item 2022-002 - Special Tests and Provisions Recommendation The Center should ensure that internal controls are in place to effectively ensure that patients receive the correct sliding fee discount. Action Taken: 1. To fix the system, so that the co-pay will roll up to the encounter and not by line item. 2. To implement at least twice an annual review to check & confirm the sliding fees in current program and billing system are consistent. 3. To implement a monthly sliding fee review, based on a sample selected to ensure the sliding fee was appropriately applied and it is according to the policy. Until we hire a Sliding Fee Specialist, the RCM Director will conduct the monthly review. And, following staff hiring, RCM Director will do routine samplings to ensure accuracy. 4. To update the Sliding Fee Guidelines document and communicate/re-train all employees involved in the process. 5. For the sliding fee patients with date of service 6.1.2020 to 12.31.2021, a report was run to capture all those patients, the billing department is working a special project to review and adjust if needed any encounter showing more than one co-pay per visit. This report is being monitored closely. Responsible Party: RCM Director Target Completion Date: June 30, 2022. Prior year audit FY2021 (06/01/2020 - 05/31/2021) was completed late by BKD, in May of 2022, the corrective action plan was implemented in June of 2022. Therefore, this finding was required for in FY2022 {06/01/2021- 05/31/2022) as well. If the Cognizant or Oversight Agency for the Audit has questions regarding this plan, please call: Rebecca Mankin, CFO at (660) 223-6212. Rebecca Mankin Chief Financial Officer

Categories

Special Tests & Provisions Internal Control / Segregation of Duties

Other Findings in this Audit

  • 47918 2022-002
    Significant Deficiency Repeat
  • 47919 2022-002
    Significant Deficiency Repeat
  • 624359 2022-002
    Significant Deficiency Repeat
  • 624360 2022-002
    Significant Deficiency Repeat
  • 624361 2022-002
    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 $4.50M
93.224 Consolidated Health Centers (community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) $3.43M
93.498 Provider Relief Fund and American Rescue Plan (arp) Rural Distribution $902,989
10.557 Special Supplemental Nutrition Program for Women, Infants, and Children $632,629
93.778 Medical Assistance Program $229,581
93.435 Innovative State and Local Public Health Strategies to Prevent and Manage Diabetes and Heart Disease and Stroke- $63,116
93.268 Immunization Cooperative Agreements $56,390
32.006 Covid-19 Telehealth Program $43,556
93.898 Cancer Prevention and Control Programs for State, Territorial and Tribal Organizations $35,291
93.526 Affordable Care Act (aca) Grants for Capital Development in Health Centers $22,646
93.436 Well-Integrated Screening and Evaluation for Women Across the Nation (wisewoman) $254