Alcona Citizens for Health, Inc.

2021-001 Program AL# 93.224/93.527 Health Center Cluster Program - Special Tests and Provisions - Significant Deficiency in Internal Control over ComplianceCriteria -Pursuant to 2 CFR 200 and the Uniform Guidance, and as noted in the compliance supplement. Health Centers must prepare and apply a sliding fee discount schedule so that the amounts owed for health center services by eligible patients are adjusted (discounted) based on the patient?s ability to pay. The Center may establish a sliding fee discount schedule, approved by the governing board, provided certain criteria in the compliance supplement are met. The Center has established an appropriate policy and sliding fee scale.Condition -The Center had instances in which sliding fee discounts were not appropriately applied based on underlying support that was provided by the patient. The staffing issues the Center faced throughout the year in navigating the COVID-19 pandemic impacted the design and implementation of internal controls over compliance with respect to the sliding fee discount.Context -A non-statistical sample of 25 sliding fee encounters was selected. In our sample we noted three sliding fee encounters were not charged the proper sliding fee.Effect -Sliding fee encounters that occur without the appropriate family size and annual income information could result in patients not being charged the appropriate fee and/or received an incorrect sliding fee discount.Questioned Costs -There were no questioned cost regarding this finding.Cause -Employees responsible for implementation and documentation of sliding fee discounts were not monitored to adequately verify processes were being performed as prescribed.Recommendation -Auditors recommend additional training for staff on sliding fee policies and procedures and management monitor and verify processes are being performed as prescribed on a reoccurring basis.Views of Responsible Officials -We concur with the audit finding. While the Center has a policy that meets the compliance requirements, management is responsible for the implementation and monitoring of those processes and procedures. Management believes additional stresses and staffing issues brought about by the COVID-19 pandemic were significant factors in causing this finding. Additional staff training on slide fee discounts is in place and monthly review and testing of compliance with Center sliding fee discount policy will be done.