Community Health Services, Inc.Non-Profit

Finding 2023-001: Special Tests and Provisions Grantor: U.S. Department of Health and Human Services Federal Program Names: Health Center Program Cluster: Health Center Program (Community Health Centers, Migrant Health Center, 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 Grant 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 Center should be implementing and monitoring procedures to properly determine, calculate and review slide fee discounts issued to patients in accordance with the Center's sliding fee scale. Condition The Center did not always calculate the proper slide fee discount based on the respective patient family size and income or have adequate documentation on file to support the proper slide fee discount. Context A test of 40 sliding fee discount transactions was performed and resulted in an instance of a sliding fee discount not being properly calculated based on the respective patient family size and income. Our sample was a statistically valid sample. Questioned Costs None. Cause The Center did not have adequate internal controls in place to effectively ensure that the proper slide fee discount was calculated based on approved documentation. Effect The Center did not comply with the appropriate rules and regulations as per the Uniform Guidance. Identification of Repeat Finding Yes - 2022.001. Recommendation The Center should implement controls to ensure that all sliding fee discounts are properly calculated 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.

Finding 2022.001: Sliding Fee Scale Documentation 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 In accordance with the Uniform Guidance, the Center must prepare and apply a sliding fee discount policy and schedule so that the amounts owed for health center services by eligible patients are adjusted (discounted) based on a patient's poverty level, which is determined by the patient's income and family size. Condition The Center did not always have the proper sliding fee documentation entered into the system for the patients, therefore, was not able to apply the sliding fee discount based on income levels. Context A test of 40 sliding fee discount transactions was performed and resulted in two instances where a patient was charged the incorrect sliding fee discount. Our sample was a statistically valid sample. Questioned Costs None. Cause The Center did not have adequate internal controls in place to effectively ensure that the proper slide fee discount is applied. Effect The Center did not comply with the appropriate rules and regulations as per the Uniform Guidance. Identification of Repeat Finding Yes ? 2021.001. Recommendation The Center should implement controls to ensure proper sliding fee discounts are provided. Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding.

Finding 2021.001: Sliding Fee Scale Documentation 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), Grants for New and Expanded Services Under the Health Center Program Federal Assistance Listing Numbers: 93.224 and 93.527 Criteria In accordance with the Uniform Guidance, the Center must prepare and apply a sliding fee discount policy and schedule so that the amounts owed for health center services by eligible patients are adjusted (discounted) based on a patient's poverty level, which is determined by the patient's income and family size. Condition The Center did not always have the proper sliding fee entered into the system for a patient, therefore, was not able to apply the sliding fee discount based on income levels. Context A test of 40 sliding fee discount transactions was performed and resulted in one instance where a patient was charged the incorrect sliding fee discount. Our sample was a statistically valid sample. Questioned Costs None. Cause The Center did not have adequate internal controls in place to effectively ensure that the proper slide fee discount is applied. Effect The Center did not comply with the appropriate rules and regulations as per the Uniform Guidance. Identification of Repeat Finding Yes. Recommendation The Center should implement controls to ensure proper slide fee discounts are provided. Views of Responsible Officials and Planning Corrective Actions In 2021, the Center implemented internal controls to mitigate the risk of missing sliding fee discount documentation. The creation of this control consisted of designing a report that would identify all sliding fee discount applicants for the specified timeframe, as well as identify whether supporting documentation had been scanned into the patient?s electronic health record. As a result of the repeated finding, the Center has now added an additional layer of review. The Director of Development, Grants and Outreach will now review all slide applications before they are scanned and entered into the electronic health record and applied to the patient?s account. The Center will continue monthly internal auditing procedures where an Eligibility Specialist haphazardly selects slide applications from the previous month to ensure compliance.

Finding 2020.001: Sliding Fee Scale Documentation Grantor: U.S. Department of Health and Human Services Federal Program Names: Health Center Program Cluster: Health Center Program, Grants for New and Expanded Services Under the Health Center Program CFDA Numbers: 93.224 and 93.527 Criteria In accordance with the Uniform Guidance, the Center must prepare and apply a sliding fee discount policy and schedule so that the amounts owed for health center services by eligible patients are adjusted (discounted) based on a patient's poverty level, which is determined by the patient's income and family size. Condition The Center did not always have documentation of the patient's income and family size available and, therefore, was not able to apply the sliding fee discount based on income levels. Context A test of 25 sliding fee discount transactions was performed and resulted in one instance where the supporting documentation was not able to be located. Our sample was a statistically valid sample. Questioned Costs None. Cause The Center did not have adequate internal controls in place to effectively ensure that the supporting documentation was present. Effect The Center did not comply with the appropriate rules and regulations as per the Uniform Guidance. Identification of Repeat Finding No. Recommendation The Center should implement controls to ensure supporting documentation is on file. Views of Responsible Officials and Planning Corrective Actions As a result of the finding, the Center has implemented additional internal controls to mitigate the risk of missing sliding fee discount documentation. The creation of this control consisted of designing a Report that would identify all sliding fee discount applicants for the specified timeframe, as well as identify whether supporting documentation had been scanned into the patient's electronic health record. Additionally, monthly internal auditing procedures are now in place where an Eligibility Specialist haphazardly selects slide applications from the previous month to ensure compliance.