CENTERPLACE HEALTH, INCNon-Profit

FINDING 2025-002 – SLIDING SCALE FEES Identification of Federal Program U.S. Department of Health and Human Services (DHHS) 93.224 / 93.527 – Health Center Cluster Special Tests and Provisions MATERIAL WEAKNESS, NON-COMPLIANCE Criteria – Health centers are required to have a schedule of discounts to be applied and adjusted based on the patients’ ability to pay and eligibility. A patient’s eligibility to pay is determined based on 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 exercises monitoring procedures to properly determine, calculate, and review sliding fee discounts to patients in accordance with the Organization’s sliding fee scale. Condition – The Organization did not perform a review of patient registration forms by employees knowledgeable about the program's parameters. Further, in many instances, inadequate documentation was maintained in patient files. Questioned Costs – The identified exceptions relate to the application of the Organization’s sliding fee discount program and resulted in variances in patient charges in both directions. Because the exceptions did not involve the use of federal award funds and did not result in unsupported, unallowable, or ineligible expenditures, there were no questioned costs associated with this finding. Context – During our audit we noted that 41 of 41 patient encounters sampled did not have evidence of review on the patient registration forms. Further, for 19 of 41 patient encounters sampled, sliding fees were calculated improperly. For 3 of 41 patient encounters sampled, proof of income was improper or inadequately documented. For 1 of 41 patient encounters sampled, billing was not performed in accordance with the proper sliding scale. Effect or Potential Effect – The Organization did not comply with the determination of sliding fee discounts based on the federal poverty guidelines in effect for the year ended April 30, 2025. In addition, the Organization may not have properly calculated the sliding fee discount given to the patients, and the discount given, if any, may not have been based on the patient’s ability to pay. Further, adequate documentation is not always maintained in patient files. Cause – Policies and procedures were not followed to ensure adequate review of patient registration forms by persons knowledgeable about the program's parameters. Further policies and procedures were not followed to ensure adequate documentation is maintained in patient files. Repeat Findings – This finding is similar to finding 2024-002 issued last year. Recommendation – We recommend that the Organization continue to train and develop new personnel on specific processes related to compliance requirements. In addition, the Organization should establish a review process to ensure that sliding scale charges are monitored and reviewed by a supervisor on a periodic basis to ensure compliance and to ensure adequate records are maintained. Views of Responsible Officials – Management agrees with the finding and the auditors’ recommendation. See Corrective Action Plan at the end of the report.

FINDING 2025-003 – LATE REPORTING Identification of Federal Program U.S. Department of Health and Human Services All Programs SIGNIFICANT DEFICIENCY, NONCOMPLIANCE Criteria – Uniform Guidance requires nonfederal entities to submit the reporting entity’s Uniform Guidance reporting package, including the audit report and completed Federal Audit Clearinghouse (FAC) Data Collection Form, to the FAC within the earlier of 30 calendar days after receipt of the auditor’s reports or nine months after fiscal year‑end (2 CFR 200.512(a)). Timely submission of the reporting package is required to facilitate federal oversight of award compliance. Condition – The Organization did not submit its required Uniform Guidance reporting package, including the reporting entity’s audit report and the FAC Data Collection Form, within the required submission timeframe. Specifically, the Uniform Guidance audit and related FAC Data Collection Form were submitted after the earlier of (1) 30 calendar days after receipt of the auditor’s reports or (2) nine months after the end of the reporting entity’s fiscal year. Questioned Costs – No questioned costs were identified as a result of this finding. Context – The condition was identified during Uniform Guidance audit planning procedures regarding auditee risk assessment. Sampling was not utilized. Effect or Potential Effect – Failure to submit the Uniform Guidance audit and FAC Data Collection Form timely increases the risk of noncompliance with Uniform Guidance reporting requirements and may result in delayed federal oversight, increased monitoring by the awarding agency, or the imposition of additional administrative conditions. Cause – Due to a delay in the compiling of records related to the audit, the Organization was not in compliance with the reporting requirements. Repeat Findings – This is not a repeat finding. Recommendation – The Organization should strengthen internal controls over Uniform Guidance audit reporting by implementing procedures to track submission deadlines, assigning responsibility for timely filing of the audit report and FAC Data Collection Form, and establishing management review processes to ensure compliance with Uniform Guidance reporting requirements. Views of Responsible Officials – Management agrees with the finding and the auditors’ recommendation. See Corrective Action Plan at the end of the report.

FINDING 2024-002 – SPECIAL TESTS AND PROVISIONS Identification of Federal Program U.S. Department of Health and Human Services 93.224 / 93.527 – Health Center Cluster MATERIAL WEAKNESS 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 to patients in accordance with the Organization’s sliding fee scale.Condition – While performing our audit, we noted that the Organization did not properly determine the sliding fee discount given to patients selected for testing based on the sliding fee scale in effect for the year ended April 30, 2024. Cause – Policies and procedures were not followed to ensure that the appropriate sliding fee discount adjustment was properly applied to all eligible transactions. Effect or Potential Effect – The Organization did not comply with the determination of sliding fee discounts based on the federal poverty guidelines in effect for the year ended April 30, 2024. In addition, the Organization may not have properly calculated the sliding fee 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 Organization did not have proper documentation to support the sliding fee discount given to 16 out of 40 patients selected for testing based on the sliding fee scale in effect for the year ended April 30, 2024. Repeat Findings – Yes Recommendation – We recommend that the Organization continue to train and develop new personnel on specific processes related to compliance requirements. In addition, the Organization should establish a review process to ensure that sliding scale charges are monitored and reviewed by a supervisor on a periodic basis to ensure compliance. Views of Responsible Officials See accompanying Corrective Action Plan

2023-02 - U.S. Department of Human Health and Services- Condition - The Organization placed one of its patients on a sliding fee for a different service than the one ultimately provided. Criteria - The Organization should maintain sliding fee applications and supporting finacial records for patients treated during the audit period to determine whether patient charges were appropriately adjusted. These patient charges are based on income and family size by applying the health center's sliding fee discount schedule according to the service that is provided. Cause - High turnover in the finance and accounting department as well as inadequate communication and training for the related processes at the Organization. Effect - The patient was charged on the correct sliding fee discount level, but for a lab visit instead of a medical visit. Recommendation - We recommend that the Organization continue to train and develop new personnel on specific processes related to compliance requirements.

Finding 2022-02 - U.S. Department of Human Health and Services- Special Tests and Provisions: Sliding Fee Discounts Condition - The Organization was unable to locate appropriate support for the sliding fee placement for two of its patients who received sliding fee discounts. Criteria - The Organization should maintain sliding fee applications and supporting finacial records for patients treated during the audit period to determine whether patient charges were appropriately adjusted. These patient charges are based on income and family size by applying the health center's sliding fee discount schedule. Cause - High turnover in the finance and accounting department as well as inadequate communication and training for the related processes at the Organization. Effect - Auditors were unable to determine if a patient was put on the correct sliding fee schedule and, therefore, given the correct discount. Recommendation - We recommend that the Organization continue to train and develop new personnel on specific processes related to compliance requirements.