Finding 479582 (2023-001)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2023
Accepted
2024-07-29
Audit: 316128
Organization: Care Alliance Health Center (CT)
Auditor: Cohnreznick LLP

AI Summary

  • Core Issue: The Organization lacks proper documentation and controls for sliding fee scale discounts, leading to incorrect calculations.
  • Impacted Requirements: Compliance with federal guidelines for determining patient eligibility and applying discounts is not being met.
  • Recommended Follow-Up: Implement stronger internal controls to ensure accurate calculations and documentation of sliding fee discounts.

Finding Text

Finding 2023.001: Special Tests and Provisions - Sliding Fee Scale Documentation - Material Weakness 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, COVID-19 - Grants for New and Expanded Services under the Health Center Program Federal Assistance Listing Numbers: 93.224 and 93.527 Criteria Health centers are required to have a corresponding schedule of discounts applied and adjusted on the basis of patients' ability to pay and their eligibility. A patient's eligibility to pay is determined on the basis of the official poverty guideline, as revised by DHHS (42 CFR Sections 51c, 107(b)(5), 56.108(b)(5) and 56.303(f)). The Organization should be implementing and monitoring procedures to properly determine, calculate and review sliding fee discounts issued to patients in accordance with the Organization's sliding fee scale. Condition The Organization did not always have the proper slide fee documentation readily available to ensure the proper slide fee discount was applied based on approved policies or the discount was calculated incorrectly. Cause The Organization did not have adequate internal controls in place to effectively ensure that all sliding fee discounts were properly calculated based on approved documentation. Effect or Potential Effect The Organization did not comply with the appropriate rules and regulations as per the Uniform Guidance. Questioned Costs None Context A test of 40 sliding fee discount transactions was performed and resulted in 26 instances where the Organization was unable to provide approved documentation, or the sliding fee discount was calculated incorrectly. Our sample was a statistically valid sample. Identification of Repeat Finding Yes Recommendation The Organization should establish a system of internal controls to ensure that all sliding fee discounts are properly calculated and supported based on family size and income. Views of Responsible Officials and Planned Corrective Actions Management agrees with the audit finding and will strengthen internal controls and accountability to correct the deficiency.

Corrective Action Plan

To Health Resources and Services Administration Care Alliance Health Center, Inc. respectfully submits the following corrective action plan for the year ended October 31, 2023. CohnReznick LLP 350 Church Street Hartford, CT 06103 Audit Period: October 31, 2023 The findings from the October 31, 2023, schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the number assigned in the schedule. Federal Award Findings: Finding 2023.001 - Special Tests and Provisions - Sliding Fee Scale Documentation Recommendation The Organization should establish a system of internal controls to ensure that all sliding fee discounts are properly calculated and supported based on family size and income. Action Taken We will invest the time and resources into improving all areas related to the Sliding Fee Scale. We will implement the following steps to our process to ensure all federal guidelines and requirements are met. 1. Documented Process: Design and implement an internal control process to ensure sliding fee discounts are accurately calculated based on family size and income. 2. Documented Procedures: Establish clear procedures and guidelines for front desk staff to follow when determining discounts, including appropriate documentation requirements, eligibility criteria, and fee structure. These procedures will be aligned with our written policy to ensure consistency and accuracy in discount calculations. 3. Training and Education: Provide training to front desk staff members responsible for determining eligibility and applying sliding fee discounts to ensure they understand the process. 4. Regular Reviews: Implement regular reviews and monthly audits to verify that all discounts are properly supported and documented. Quarterly reviews will be conducted to verify compliance, identify areas for improvement, and evaluate the effectiveness of the sliding scale fee program to ensure it meets our patients' needs and complies with all federal guidelines. Responsible Parties: 1. The Controller and revenue cycle staff will develop the written procedure. 2. The Clinical Support Supervisor and revenue cycle staff will overseE3 the training. 3. The Revenue Cycle Manager_will monitor adherence to the procedure, conduct regular monthly audits, and report results to the Controller. 4. The Controller will conduct quarterly documentation reviews of the internal audit results. Timeline: 1. Procedure draft completion: Completed 2. Review and approval by senior management: July 24, 2024 3. Initial staff training session: July 25, 2024 4. Follow-up training sessions: As needed 5. Monthly compliance audits: Starting September 1, 2024

Categories

Special Tests & Provisions Subrecipient Monitoring Eligibility HUD Housing Programs Material Weakness Internal Control / Segregation of Duties

Other Findings in this Audit

  • 479583 2023-001
    Material Weakness Repeat
  • 479584 2023-001
    Material Weakness Repeat
  • 479585 2023-001
    Material Weakness Repeat
  • 479586 2023-002
    Material Weakness
  • 479587 2023-002
    Material Weakness
  • 479588 2023-002
    Material Weakness
  • 479589 2023-002
    Material Weakness
  • 1056024 2023-001
    Material Weakness Repeat
  • 1056025 2023-001
    Material Weakness Repeat
  • 1056026 2023-001
    Material Weakness Repeat
  • 1056027 2023-001
    Material Weakness Repeat
  • 1056028 2023-002
    Material Weakness
  • 1056029 2023-002
    Material Weakness
  • 1056030 2023-002
    Material Weakness
  • 1056031 2023-002
    Material Weakness

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) $1.72M
93.527 Affordable Care Act (aca) Grants for New and Expanded Services Under the Health Center Program $150,776