Finding 499549 (2023-002)

Significant Deficiency

Requirement

Questioned Costs

Year

2023

Accepted

2024-09-30

Audit: 322404

Organization: Lakewood Resource & Referral Center-D/b/a/ Center for Health Education (NJ)

Auditor: Cohnreznick LLP

AI Summary

Core Issue: The Center failed to accurately determine sliding fee discounts for some patients based on their ability to pay.
Impacted Requirements: Compliance with federal poverty guidelines for sliding fee discounts was not met, affecting patient eligibility assessments.
Recommended Follow-Up: Provide training for registration staff, implement regular supervisory reviews, and conduct internal audits to ensure proper calculations 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 2023-002 - Special Tests and Provisions 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)). Statement of Condition While performing our audit, we noted that the Center did not properly determine the sliding fee discount category given to certain patients selected for testing based on the sliding fee scale in effect for the year ended December 31, 2023. Cause The condition can be attributed to human error and the lack of internal controls to review and ensure that the proper sliding fee documentation is being maintained and applied. 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 may not have properly calculated the sliding fee or discount given to the patients and the discount given, if any, may not have been based on the patient's ability to pay. Questioned Costs None Context While performing our audit, we noted that the Center did not properly determine the sliding fee discount category given to two out of forty three patients selected for testing based on the sliding fee scale in effect for the year ended December 31, 2023. Identification as a Repeat Finding This is not a repeat finding. Recommendation We recommend that proper training be given to employees at registration to ensure that the sliding fee discounts are being properly calculated. Supervisors should monitor and review the sliding fee calculations on a periodic basis to ensure compliance with the sliding fee scale. In addition, management should conduct internal audits to ensure the sliding fee is calculated properly. Views of Responsible Official Management of the Center has reached out to necessary employees with guidelines to ensure that sliding fee discounts are given to eligible patients. Additionally, procedures have been put in place to ensure that the sliding scale fees are calculated properly.

Corrective Action Plan

CORRECTIVE ACTION PLAN September 27, 2024 Health Resources and Services Administration Lakewood Resource and Referral Center, Inc. D/B/A Center for Health Education, Medicine and Dentistry respectfully submits the following corrective action plan for the year ended December 31, 2023. ____________________________________________________________________________________ CohnReznick LLP 1301 Avenue of the Americas New York, NY 10019 Audit Period: December 31, 2023 The findings from the December 31, 2023 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the number assigned in the schedule. FINDINGS – FINANCIAL STATEMENT FINDINGS Finding 2023-001 – Account Analyses MATERIAL WEAKNESS Recommendation We recommend that the Center ensure that all accounting records are analyzed and reconciled on a monthly basis. We also recommend that necessary procedures be enhanced whereby an employee of the Center consistently reviews and follows up on receivables and adjusts the reserves for those receivables appropriately. This will help accurately reflect the cash realizable value of receivables. This will provide the Center with a stronger accounting of patient services receivable with which to better manage cash collections. We also recommend that the Center perform the patient services revenue reconciliation by payor source on a monthly basis. This would help the Center determine whether patient services revenue is being properly recorded by payor source. Action Taken Management of the Center agrees with the finding and has started to work with a new general ledger software package at the start of 2024, to better accommodate monthly reconciliations. We will also ensure that these analyses and reconciliations will be reviewed on a consistent and timely basis. There has been steady improvement throughout 2024, and it is expected to be complete by the end of 2024. FINDINGS – FEDERAL AWARDS PROGRAM AUDIT U.S. Department of Health and Human Services, COVID-19 Health Centers Program Cluster (Assistance Listing Number 93.224/93.527) Finding 2023-002 – Special Tests and Provisions SIGNIFICANT DEFICIENCY Recommendation We recommend that proper training be given to employees at registration to ensure that the sliding fee discounts are being properly calculated. Supervisors should monitor and review the sliding fee calculations on a periodic basis to ensure compliance with the sliding fee scale. In addition, management should conduct internal audits to ensure the sliding fee is calculated properly. Action Taken Management of the Center is providing additional training to the relevant staff that deal with the Sliding Fee Discount (SFD). These staff members include front desk staff, financial counselors, and the general finance and billing departments, as applicable. The SFD Policy and SFD Scale are being reviewed by management to ensure that the guidelines and procedures are clear. Revisions to the SFD Policy and SFD Scale will be made, and Board approved, if necessary to improve clarity. To ensure that the SFD is being properly calculated in accordance with the SFD Scale, a monitoring process will be included, which may include internal periodic audits by supervisors. All changes will be finalized and implemented by the end of 2024. If the Health Resources and Services Administration has questions regarding this plan, please call Scott Jackson, Chief Financial Officer at (732) 364-2144 x6138. Sincerely yours, Scott Jackson, CFO

Other Findings in this Audit

499550 2023-002

Significant Deficiency
499551 2023-002

Significant Deficiency
499552 2023-002

Significant Deficiency
1075991 2023-002

Significant Deficiency
1075992 2023-002

Significant Deficiency
1075993 2023-002

Significant Deficiency
1075994 2023-002

Significant Deficiency

Programs in Audit

ALN	Program Name	Expenditures
93.527	Affordable Care Act (aca) Grants for New and Expanded Services Under the Health Center Program	$942,525
93.224	Community Health Centers	$644,678
93.526	Grants for Capital Development in Health Centers	$640,924
93.391	Activities to Support State, Tribal, Local and Territorial (stlt) Health Department Response to Public Health Or Healthcare Crises	$593,860
97.036	Disaster Grants - Public Assistance (presidentially Declared Disasters)	$442,240
21.027	Coronavirus State and Local Fiscal Recovery Funds	$425,000
93.498	Provider Relief Fund and American Rescue Plan (arp) Rural Distribution	$116,698
93.268	Immunization Cooperative Agreements	$51,255
59.077	Community Navigator Pilot Program	$51,000
93.011	National Organizations of State and Local Officials	$34,695
97.024	Emergency Food and Shelter National Board Program	$33,008
17.225	Unemployment Insurance	$21,852
10.561	State Administrative Matching Grants for the Supplemental Nutrition Assistance Program	$16,574