Finding 480347 (2023-001)

Significant Deficiency Repeat Finding
Requirement
N
Questioned Costs
-
Year
2023
Accepted
2024-08-05
Audit: 316606
Organization: Carearc, INC (KS)
Auditor: Cohnreznick LLP

AI Summary

  • Core Issue: The Organization failed to maintain proper documentation for sliding fee discounts, leading to incorrect calculations.
  • Impacted Requirements: Compliance with federal guidelines for determining patient eligibility based on income and poverty levels was not met.
  • Recommended Follow-Up: Implement stronger internal controls to ensure accurate calculation and documentation of sliding fee discounts.

Finding Text

Finding 2023.001: Special Tests and Provisions - Sliding Fee Discounts 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. 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 The Organization did not comply with the appropriate Special Tests and Provisions rules and regulations as per the Uniform Guidance in 2023. Questioned Costs None Context A test of 40 sliding fee discount transactions was performed and resulted in two 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 Repeat finding of 2022-01 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

Finding 2023.001 - 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 CareArc was notified of the 2023 annual audit finding related to Sliding Fee Discounts being applied incorrectly according to the Health Center Program Compliance Manual and out of compliance with our sliding fee policy. CareArc's CFO was aware of the incorrect slide adjustments during the sampling process of the audit. The two patients on Slide B that should have received 50% discount, only received 49% ($3.00 miscalculation) as our electronic medical records did not identify an internal lab as being all inclusive of the same-day office visit. The corrective action plan was to have the Electronic Medical Records system recognize internal labs as being all inclusive of the same-day office visit. This issue was identified by CareArc through an internal audit in September 2023 and we began working with Health Choice Network (HCN). HCN is our vendor that helps program our electronic medical records system. HCN has helped CareArc correct the system going forward. CareArc is working with HCN on creating a report on historical slide applications to correct accounts earlier in 2023. CareArc was able to manually correct the two identified patient accounts. The corrective action plan is still in process of being implemented by CareArc with the assistance of HCN/EPIC with an estimated completion in September 2024. If there are any question regarding this plan, please e-mail Seresa Howe at showe@carearc.org.

Categories

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

Other Findings in this Audit

  • 480348 2023-001
    Significant Deficiency Repeat
  • 480349 2023-001
    Significant Deficiency Repeat
  • 480350 2023-001
    Significant Deficiency Repeat
  • 1056789 2023-001
    Significant Deficiency Repeat
  • 1056790 2023-001
    Significant Deficiency Repeat
  • 1056791 2023-001
    Significant Deficiency Repeat
  • 1056792 2023-001
    Significant Deficiency Repeat

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) $868,311
93.526 Affordable Care Act (aca) Grants for Capital Development in Health Centers $603,684
10.557 Special Supplemental Nutrition Program for Women, Infants, and Children $316,837
93.527 Affordable Care Act (aca) Grants for New and Expanded Services Under the Health Center Program $120,004
93.575 Child Care and Development Block Grant $113,494
93.268 Immunization Cooperative Agreements $103,531
93.323 Epidemiology and Laboratory Capacity for Infectious Diseases (elc) $75,605
93.069 Public Health Emergency Preparedness $65,974
93.994 Maternal and Child Health Services Block Grant to the States $43,354
93.366 State Actions to Improve Oral Health Outcomes and Partner Actions to Improve Oral Health Outcomes $8,750