GREATER SEACOAST COMMUNITY HEALTHNon-Profit

Finding Number: 2024 001 Finding Type: Significant Deficiency in Internal Controls Over Compliance related to Special Tests and Provisions Information on the Federal Program: Program Name: Health Center Program Cluster (AL numbers 93.224 and 93.527) Grant Awards: 2 H80CS04210 19 00 from May 1, 2023 through April 30, 2024 and 5 H80CS04210 29 00 from May 1, 2024 through April 30, 2025 Agency: U.S. Department of Health and Human Services, Health Resources and Services Administration Pass Through Entity: N/A Criteria: In accordance with Section 330(k)(3)(G) of the Public Health Services Act (42 U.S. Code § 254b), as an FQHC, the Organization must have a sliding fee discount program in which the Organization’s fee schedule is discounted based on a patient’s ability to pay. In accordance with their policy, the Organization will monitor the accuracy of the discounts provided to patients by a monthly random audit of 15 visits where a sliding fee discount adjustment was received. Condition: The Organization did not perform monitoring activities as outlined above from July 2024 through December 2024 as required by the Organization's sliding fee discount policy. Cause: The Organization was unable to complete the task as expected due to an exceptionally high workload during this period. They were managing multiple priorities, which required their immediate attention, and as a result, were not able to allocate the necessary time to this particular responsibility. Effect: It is possible the Organization may not apply sliding fee discounts to patient charges consistent with its sliding fee discount program and these errors may not be detected and corrected in a timely manner. Questioned Costs: None Repeat Finding: No Recommendation: To help maintain compliance with the Organization’s sliding fee discount program and related policy, we recommend the Organization strengthen its internal controls by implementing the following: 1. Establish a Formal Monitoring Calendar: Develop and maintain a documented monitoring calendar that includes monthly deadlines and responsible personnel for completing the required audits. This calendar should be reviewed and approved by supervisory staff and integrated into regular compliance reporting. 2. Assign Backup Personnel: Designate and train at least one backup staff member to perform sliding fee discount audits during periods of high workload or staff absences in order to maintain continuity and timely completion of required monitoring activities. 3. Monthly Oversight Review: Require supervisory review and sign off on the completion of each monthly audit to verify that the monitoring activities were conducted and documented appropriately. Views of a Responsible Official and Corrective Action Plan: Management agrees with the finding and will implement the recommendations above and maintain consistency with their internal monitoring procedures moving forward.

Significant Deficiency in Internal Controls Over Compliance related to Special Tests and Provisions Program Name: Health Center Program Cluster (AL numbers 93.224 and 93.527) Grant Awards: 2 H80CS04210-19-00 from May 1, 2023 through April 30, 2024 and 5 H80CS04210-29-00 from May 1, 2024 through April 30, 2025 Agency: U.S. Department of Health and Human Services, Health Resources and Services Administration Pass-Through Entity: N/AIn accordance with Section 330(k)(3)(G) of the Public Health Services Act (42 U.S. Code § 254b), as an FQHC, the Organization must have a sliding fee discount program in which the Organization’s fee schedule is discounted based on a patient’s ability to pay. In accordance with their policy, the Organization will monitor the accuracy of the discounts provided to patients by a monthly random audit of 15 visits where a sliding fee discount adjustment was received. The Organization did not perform monitoring activities as outlined above from July 2024 through December 2024 as required by the Organization's sliding fee discount policy The Organization was unable to complete the task as expected due to an exceptionally high workload during this period. They were managing multiple priorities, which required their immediate attention, and as a result, were not able to allocate the necessary time to this particular responsibility. It is possible the Organization may not apply sliding fee discounts to patient charges consistent with its sliding fee discount program and these errors may not be detected and corrected in a timely manner.

Finding Number: 2024 001 Finding Type: Significant Deficiency in Internal Controls Over Compliance related to Special Tests and Provisions Information on the Federal Program: Program Name: Health Center Program Cluster (AL numbers 93.224 and 93.527) Grant Awards: 2 H80CS04210 19 00 from May 1, 2023 through April 30, 2024 and 5 H80CS04210 29 00 from May 1, 2024 through April 30, 2025 Agency: U.S. Department of Health and Human Services, Health Resources and Services Administration Pass Through Entity: N/A Criteria: In accordance with Section 330(k)(3)(G) of the Public Health Services Act (42 U.S. Code § 254b), as an FQHC, the Organization must have a sliding fee discount program in which the Organization’s fee schedule is discounted based on a patient’s ability to pay. In accordance with their policy, the Organization will monitor the accuracy of the discounts provided to patients by a monthly random audit of 15 visits where a sliding fee discount adjustment was received. Condition: The Organization did not perform monitoring activities as outlined above from July 2024 through December 2024 as required by the Organization's sliding fee discount policy. Cause: The Organization was unable to complete the task as expected due to an exceptionally high workload during this period. They were managing multiple priorities, which required their immediate attention, and as a result, were not able to allocate the necessary time to this particular responsibility. Effect: It is possible the Organization may not apply sliding fee discounts to patient charges consistent with its sliding fee discount program and these errors may not be detected and corrected in a timely manner. Questioned Costs: None Repeat Finding: No Recommendation: To help maintain compliance with the Organization’s sliding fee discount program and related policy, we recommend the Organization strengthen its internal controls by implementing the following: 1. Establish a Formal Monitoring Calendar: Develop and maintain a documented monitoring calendar that includes monthly deadlines and responsible personnel for completing the required audits. This calendar should be reviewed and approved by supervisory staff and integrated into regular compliance reporting. 2. Assign Backup Personnel: Designate and train at least one backup staff member to perform sliding fee discount audits during periods of high workload or staff absences in order to maintain continuity and timely completion of required monitoring activities. 3. Monthly Oversight Review: Require supervisory review and sign off on the completion of each monthly audit to verify that the monitoring activities were conducted and documented appropriately. Views of a Responsible Official and Corrective Action Plan: Management agrees with the finding and will implement the recommendations above and maintain consistency with their internal monitoring procedures moving forward.

Significant Deficiency in Internal Controls Over Compliance related to Special Tests and Provisions Program Name: Health Center Program Cluster (AL numbers 93.224 and 93.527) Grant Awards: 2 H80CS04210-19-00 from May 1, 2023 through April 30, 2024 and 5 H80CS04210-29-00 from May 1, 2024 through April 30, 2025 Agency: U.S. Department of Health and Human Services, Health Resources and Services Administration Pass-Through Entity: N/AIn accordance with Section 330(k)(3)(G) of the Public Health Services Act (42 U.S. Code § 254b), as an FQHC, the Organization must have a sliding fee discount program in which the Organization’s fee schedule is discounted based on a patient’s ability to pay. In accordance with their policy, the Organization will monitor the accuracy of the discounts provided to patients by a monthly random audit of 15 visits where a sliding fee discount adjustment was received. The Organization did not perform monitoring activities as outlined above from July 2024 through December 2024 as required by the Organization's sliding fee discount policy The Organization was unable to complete the task as expected due to an exceptionally high workload during this period. They were managing multiple priorities, which required their immediate attention, and as a result, were not able to allocate the necessary time to this particular responsibility. It is possible the Organization may not apply sliding fee discounts to patient charges consistent with its sliding fee discount program and these errors may not be detected and corrected in a timely manner.

Finding Number: 2021-001 Finding Type: Compliance - Special Tests and Provisions Information on the Federal Program: Program Name: Health Center Program Cluster (AL numbers 93.224 and 93.527) Grant Award: 5 H80CS04210-16 from May 1, 2020 through April 30, 2021 and 5 H80CS04210-17 from May 1, 2021 through April 30, 2022 Agency: U.S. Department of Health and Human Services, Health Resources and Services Administration Pass-Through Entity: N/A Criteria: In accordance with Section 330(k)(3)(G) of the PHS Act (42 U.S. Code ? 254b), as an FQHC, the Organization must have a sliding fee discount program in which the Organization?s fee schedule is discounted based on a patient?s ability to pay. Condition Found and Context: The Organization has not applied sliding fee discounts to patient charges consistent with its sliding fee discount program. Through testing a statistically valid sample of transactions for the appropriate application of the Organization's sliding fee discount program to 25 individual patient balances, we noted the sliding fee discount applied was not consistent with the Organization's sliding fee discount policy for two dental patients. One patient qualified for a Category 2 discount based on income and family size but was awarded a Category 1 discount, which resulted in the patient paying $82 less than required under the program. One patient had dental service which included an outside lab fee, which is not subject to discount, and received an incorrect discount due to a system error with the calculation of the lab fee resulting in the patient paying $55 less than required under the program. Cause and Effect: The Organization has a complex dental sliding fee discount schedule which includes flat fee amounts for Category 1 patients and percentage discounts for the other discount categories as well as excluded outside lab fees. As a result of this complexity, the Organization has implemented monthly monitoring procedures which include the sampling of discounts provided to ensure the discounts were applied to patient accounts appropriately. The volume of discounts provided annually does not allow for 100% review of all patient discounts and the inherent nature of sampling will not result in all errors will be identified and corrected. As a result, it is possible the Organization may not apply sliding fee discounts to patient charges consistent with its sliding fee discount program. Questioned Costs: None Repeat Finding: No Recommendation: We recommend management review the complexity of the Organization?s dental sliding fee discount schedule and consider whether modifications to the scale would better allow the billing system to correctly apply sliding fee discounts to dental patients without the need for staff correction. We also recommend management consider increasing the number of dental transactions reviewed as part of the Organization's internal monitoring procedures. Views of a Responsible Official and Corrective Action Plan: Management agrees with the finding and will review the dental sliding fee discount schedule and internal monitoring procedures for opportunities for improvement to increase compliance with the program requirements.

Finding Number: 2019-001 Information on the Federal Program: Program Name: Health Center Program Cluster (CFDA numbers 93.224 and 93.527) Grant Award: 6 H80CS04210-14 from May 1, 2018 through April 30, 2019 and 2 H80CS04210-15 from May 1, 2019 through April 30, 2020 Agency: U.S. Department of Health and Human Services, Health Resources and Services Administration Pass-Through Entity: N/A Criteria: In accordance with 42 USC 254(k)(3)(F), the Organization must prepare and apply a sliding fee discount schedule so that the amounts owed for the Organization?s services by eligible patients are adjusted (discounted) based on the patient?s ability to pay. Condition Found and Context: Through testing the application of the Organization's sliding fee discount program to 25 individual patient balances, we noted the sliding fee discount applied was not consistent with the Organization's sliding fee discount policy for one patient. The total difference between the discount and the policy was 1% of the sample tested. Cause and Effect: The Organization?s policy allows for retroactive discounts to services provided 30 days prior to the completion of the sliding fee application. The process for retroactive discounts is a manual process. The error in our testing was related to a service date with a retroactive sliding fee discount and was the result of human error and was not caught by internal monitoring procedures. The Organization stopped performing internal monitoring procedures early in 2019 as the monthly testing was not identifying errors. The error resulted in a patient paying less than what was required under the Organization sliding fee discount program. Questioned Costs: None Repeat Finding: No Recommendation: We recommend the Organization reinstate internal monitoring procedures and perform periodic testing of sliding fee discounts to help ensure the discounts are provided consistent with the Organization?s sliding fee discount policy. Views of a Responsible Official and Corrective Action Plan: Management agrees with the finding. Routine and timely documented reviews of sliding fee discounts will be completed to ensure compliance with the Organization's sliding fee discount program.

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