COLUMBIA VALLEY COMMUNITY HEALTH

Federal agency: U.S. Department of Health and Human Services Federal program title: Health Center Program Cluster CFDA Number: 93.224 and 93.527 Award Period: April 1, 2020 through March 31, 2021 Type of Finding: Significant Deficiency in Internal Control over Compliance and Compliance Criteria or specific requirement: Special Tests and Provisions: Sliding Fee Discounts (42 USC 254(k)(3)(g); 42 CFR section 51c.303(g) and 42 CFR section 56.303(f)). Condition: Columbia Valley Community Health?s (the Organization) sliding fee discount program provides discounts to uninsured patients based on the patient?s income and poverty levels. During our audit we noted instances of an inaccurate sliding fee discount provided. Additionally, under the Organization?s policy supporting documentation used to determine a patient?s eligibility for a sliding fee discount should be maintained as part of the patient?s record. There were instances noted where a lack of sliding fee application documentation was maintained. Questioned costs: None. Context: An initial sample of 25 encounters were tested in relation to the sliding fee discount program. Of the 25 encounters tested two of the selections did not have a sliding fee application retained in the patient record per the Organization?s policy to document verification of a patient?s eligibility for the sliding fee discount. As a result an additional 34 encounters were selected and tested for compliance with the sliding fee discount policy. Of the additional 34 encounters, two selections were found to not have received the proper sliding fee discount based upon the patient?s application and one additional selection did not have a sliding fee application retained in the patient record for a total of 3 additional errors. Cause: The Organization did not comply with their sliding fee policy or maintain proper documentation of sliding fee eligibility. Effect: Improper sliding fee discounts were given to patients. Repeat finding: No. Recommendation: Management should review their policies and procedures with the personnel responsible for providing the sliding fee discount and for ensuring that documentation is maintained to support the eligibility of sliding fee discount. We also recommend that management implement, monthly or quarterly, a self audit process of newly approved sliding fee discount recipients and their associated patient record. Views of responsible officials: There is no disagreement with the audit finding.

U.S. Department of Health and Human Services Columbia Valley Community Health respectfully submits the following corrective action plan for the year ended March 31, 2021. Audit period: April 1, 2020 through March 31, 2021 The finding from the schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the number assigned in the schedule. FINDINGS?FINANCIAL STATEMENT AUDIT There were no financial statement findings in the audit period. FINDINGS?FEDERAL AWARD PROGRAMS AUDITS 2021-001 Health Center Program Cluster ? CFDA No. 93.224 and 93.527 Recommendation: The Organization should ensure that all sliding fee applications are reviewed and approved prior to entry in the practice management system and that documentation is maintained to ensure they can support the sliding fee discounts provided to patients. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The sliding fee discount process and policy have been reviewed with staff which covers the qualification for the slide, calculations, and required documentation. Audits are performed for all sliding fee discounts, corrections are made as needed, documentation retention is verified, and staff are retrained as needed. The process of uploading documentation for retention was changed to meet the new requirements of Athena, our EMR. Name(s) of the contact person(s) responsible for corrective action: Mike Romine, Chief Financial Officer Planned completion date for corrective action plan: March 31, 2022 If the U.S. Department of Health and Human Services has questions regarding this plan, please call Mike Romine, Chief Financial Officer at (509)662-600.