Finding 498811 (2023-002)

Material Weakness
Requirement
N
Questioned Costs
-
Year
2023
Accepted
2024-09-27
Audit: 321531
Organization: Catherine's Health Center (MI)

AI Summary

  • Core Issue: There is a material weakness in internal controls over sliding fee discounts, leading to incorrect applications and missing documentation.
  • Impacted Requirements: The Center failed to comply with federal poverty guidelines and its own policies regarding patient eligibility for sliding fee discounts.
  • Recommended Follow-Up: Provide employee training and implement monitoring procedures to ensure accurate application and documentation of sliding fee discounts.

Finding Text

AL# 93.224 and 93.527 Health Center Cluster - Material weakness in internal control over federal award program - Special Tests and Provisions: Sliding Fee Discounts 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) and 56.303(f)). The Center should be implementing and monitoring procedures to properly determine, calculate, and review sliding fee discounts issued to patients in accordance with the Center's sliding fee scale. Condition - During audit procedures of sliding fee adjustments there were multiple instances where the slide was inappropriately applied based on the sliding fee discount schedule in place at the time of service and multiple applications were missing. Questioned Costs - None. Context- A nonstatistical sample of 40 sliding fee adjustment transactions were selected for testing. Of this sample two errors were identified as incorrect sliding fee was given to the patient and four sliding fee applications were missing from the client's records. Potential Effect - The Center did not comply with the determination of sliding fee discounts based on the federal poverty guidelines in effect for the year ended December 31, 2023. In addition, the Center did not comply with its policies and procedures and may have not properly calculated the sliding fee or discount given to the patients and the discount given, in any, may not have been based on the patient's ability to pay. Cause - The condition is attributable to human error and the lack of internal controls to monitor and review to ensure that the proper sliding fee documentation is being collected and applied. Recommendation - We recommend the Center provide proper training to employees to ensure that the sliding fee discounts are being properly applied and documented. In addition to implementing policies and procedures to ensure the sliding fee discounts are being properly monitored and supervised on a periodic basis to ensure compliance. Views of Responsible Officials and Planned Corrective Actions - Management concurs with this finding and will ensure that controls are established to ensure proper training and monitoring of the sliding fee discounts.

Corrective Action Plan

Action Taken – We concur with the audit finding. While the Center has a policy that meets the compliance requirements, management is responsible for the implementation and monitoring of those processes and procedures. Additional staff training on slide fee discounts is in place and quarterly review and testing of compliance with Center sliding fee discount policy is ongoing.

Categories

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

Other Findings in this Audit

  • 498812 2023-002
    Material Weakness
  • 498813 2023-002
    Material Weakness
  • 498814 2023-002
    Material Weakness
  • 1075253 2023-002
    Material Weakness
  • 1075254 2023-002
    Material Weakness
  • 1075255 2023-002
    Material Weakness
  • 1075256 2023-002
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
93.224 Community Health Centers $2.95M
93.498 Provider Relief Fund and American Rescue Plan (arp) Rural Distribution $327,904
93.526 Fip Verification $40,855
93.527 Affordable Care Act (aca) Grants for New and Expanded Services Under the Health Center Program $5,503
93.436 Well-Integrated Screening and Evaluation for Women Across the Nation (wisewoman) $612