Finding 559739 (2024-001)

Material Weakness Repeat Finding

Requirement

Questioned Costs

Year

2024

Accepted

2025-05-06

Audit: 355653

Organization: Care Alliance Health Center (CT)

Auditor: Cohnreznick LLP

AI Summary

Core Issue: The Organization lacks proper documentation and internal controls for applying sliding fee discounts, leading to incorrect calculations.
Impacted Requirements: Failure to comply with federal guidelines for determining patient eligibility and discount application as per the Health Center Program.
Recommended Follow-Up: Implement a robust system of internal controls to ensure accurate calculation and documentation of sliding fee discounts based on family size and income.

Finding Text

Finding 2024.001: 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 - Grants for New and Expanded Services under the Health Center Program Federal Assistance Listing Numbers: 93.224 and 93.527 Federal Award Identification Number and Year: H80CS00029 - 2023 and 2024, H2ECS50128 - 2023, H8LCS51483 - 2023, H8GCS48563 - 2023 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 27 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 see prior year Finding 2023.001 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, 2024. CohnReznick LLP 350 Church Street Hartford, CT 06103 Audit Period: October 31, 2024 The findings from the October 31, 2024 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 2024.001 - 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. Care for you. Care for me. Care for all. Our mission is to provide high-quality, comprehensive medical and dental care, patient advocacy and related services to people who need them most, regardless of their ability to pay. info@carealliance.org • www.carealliance.org Responsible Parties: 1. The Controller and revenue cycle staff will develop the written procedure. 2. The Clinical Support Supervisor and revenue cycle staff will oversee 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.

Other Findings in this Audit

559740 2024-001

Material Weakness Repeat
1136181 2024-001

Material Weakness Repeat
1136182 2024-001

Material Weakness Repeat

Programs in Audit

ALN	Program Name	Expenditures
93.224	Health Center Program (community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care)	$4.76M
93.527	Grants for New and Expanded Services Under the Health Center Program	$75,826
93.526	Grants for Capital Development in Health Centers	$38,212