OUTREACH COMMUNITY HEALTH CENTERS, INC.Non-Profit

Criteria Health centers must prepare and apply a sliding fee discount schedule (SFDS) so that the amounts owed for health center services by eligible patients are adjusted (discounted) based on the patient’s ability to pay. The health center must also implement internal controls to ensure that the calculation is determined correctly and is supported. Condition Wipfli reviewed 40 sliding fee charges to test if the amount charged was calculated properly based on the patients’ income level, family size and in compliance with Outreach Community Health Center's’ sliding fee policy. Wipfli noted in 4 of the 40 cases, a sliding fee discount was given to a patient who did not qualify for the a sliding fee discount or support was not maintained for the discount given, and in 2 of the 40 cases, Wipfli noted the amount of the sliding fee adjustment applied to the patient's account was incorrectly determined. Cause and Effect Outreach Community Health Centers did not consistently follow the Organization’s policies for approving, documenting and calculating charges for services when using the sliding fee scale and sliding fee discounts were applied in error to certain accounts due to staff incorrectly marking them as sliding fee patients. Auditor’s Recommendation Implement effective internal controls that ensure that all policies and procedures related to the sliding fee are followed and that sliding fee discounts are reviewed to determine that the proper discounts were applied and documentation was retained or documented. Internal controls would include review and approval on all sliding fee determinations and a review of discounts given to sliding fee patients in order to detect sliding fee discounts given in error. View of Responsible Officials Management agrees with the findings and has committed to a corrective action plan.

Criteria Health centers must prepare and apply a sliding fee discount schedule (SFDS) so that the amounts owed for health center services by eligible patients are adjusted (discounted) based on the patient’s ability to pay. The health center must also implement internal controls to ensure that the calculation is determined correctly and is supported. Condition Wipfli reviewed 40 sliding fee charges to test if the amount charged, was calculated properly based on the patients’ income level, family size and in compliance with Outreach Community Health Center's’ sliding fee policy. Wipfli noted that 12 of the charges to sliding fee were produced in Outreach's system due to an improper box being checked which caused the write off of the balance in the system as a sliding fee charge to patients not eligible for sliding fee. Wipfli noted that in 7 of the 40 cases, a sliding fee discount was given to a patient who did not qualify for the a sliding fee discount or support was not maintained for the discount given, and Wipfli noted 1 out of 40 cases where the amount of the sliding fee adjustment applied to the patient's account was incorrectly determined. Cause and Effect Outreach Community Health Centers did not consistently follow the Organization’s policies for approving, documenting and calculating charges for services when using the sliding fee scale and sliding fee discounts were applied in error to certain accounts due to staff incorrectly marking them as sliding fee patients. Auditor’s Recommendation Implement effective internal controls that ensure that all policies and procedures related to the sliding fee are followed and that sliding fee discounts are reviewed to determine that the proper discounts were applied and documentation was retained or documented. Internal controls would include review and approval on all sliding fee determinations and a review of discounts given to sliding fee patients in order to detect sliding fee discounts given in error. View of Responsible Officials Management agrees with the findings and has committed to a corrective action plan.

Finding 2022-005: Sliding Fee Assistance listing No. 93.224 Health Center Program Cluster Questioned Costs - N/A Criteria Health centers must prepare and apply a sliding fee discount schedule (SFDS) so that the amounts owed for health center services by eligible patients are adjusted (discounted) based on the patient’s ability to pay. The health center must also implement internal controls to ensure that the calculation is determined correctly and is supported. Condition Wipfli reviewed 40 sliding fee charges to test if the amount charged, was calculated properly based on the patients’ income level and in compliance with Outreach Community Health Center's’ sliding fee policy. Wipfli noted that 7 of the charges were not properly determined based on patients family size and income level, in addition Wipfli noted that 6 files did not contain approval of the sliding fee calculation. Cause and Effect Outreach Community Health Centers did not consistently follow the Organization’s policies for approving, documenting and calculating charges for services when using the sliding fee scale. As a result patients two patients were charged the improper sliding fee amount, one patient was included in the sliding fee program without documentation of family size or income, and the sliding fee discount was applied to four patient balances as Outreach Community Health Centers wrote off the account. Auditor’s Recommendation Implement effective internal controls that ensure that all policies and procedures related to the sliding fee are followed and that sliding fee discounts are reviewed to determine that the proper discounts were applied and documentation was retained or documented. Internal controls would include review and approval on alll slding fee determinations and a review of discounts given to sliding fee patients. View of Responsible Officials Management agrees with the findings and has committed to a corrective action plan.

Finding 2021-002 Grant Reporting AL # 93.498 Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution Questioned Costs - None Criteria Maintenance of complete and accurate accounting records in accordance with grant reporting requirements ensures that timely, accurate and useful information is available to management, those charged with governance, and grantors. Internal controls must be in place to ensure accurate grant reporting. Fundamental to a good system of internal controls are thorough review processes, accurate record keeping and timely reconciliations. Condition Wipfli noted that reporting requirements for the Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution grant required reporting of expenses by quarter for the grant period. Wipfli noted that Outreach Community Health Centers, Inc. reported all expenses to have been incurred in the fourth quarter of 2021, while the expenses were incurred in multiple quarters during the year. Cause and Effect All grant expenses were reported as being incurred in the fourth quarter of 2021 rather then in the quarter in which they were actually incurred. Auditor?s Recommendation Implement effective internal controls that ensure that all reporting is accurate. Internal controls would include review and approval on all reporting on grants. View of Responsible Officials Management agrees with the findings and has committed to a corrective action plan.

Agencies: U.S. Department of Health and Human Services CFDA Number: Health Center Program Cluster: 93.224 Programs: Health Center Program Cluster; Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) Criteria: The Organization is required to have controls in place to monitor compliance with the requirements of their grants, including controls over special tests and provisions relating to the application of the sliding fee discount. Statement of condition: The Organization did not have adequate and effective controls over compliance in place as it relates to applying the sliding fee discount. We found situations where individuals were not appropriately charged based on the sliding fee policy in place. Questioned Costs: Seven errors were identified during our testing. The amount of questioned costs could not be determined. Context: A total of 639 individuals received the sliding fee discount in 2019. A sample of 60 individuals was selected and tested for compliance with the Organization's sliding fee policy. Seven known compliance errors were found during the testing of the 60 individuals. Effect: Noncompliance with application of the Organization's sliding fee discount went undetected due to a lack of effective controls over compliance. Cause: Management has indicated that they relied on user inputs and their software to calculate the appropriate fee based on the Organization's policy. Recommendation: We recommend management review their controls over compliance relating to the Organization's compliance with the sliding fee discount to ensure discounts are appropriately charged, reviewed timely, and management maintains documentation of the review. Management's Response: OCHC will began training staff members on "HRSA Sliding Fee Scale ("SFS") PIN Requirements, Calculating Annual Income and FPL, Completing SFS Application, ?What is Acceptable Documentation?? and completing the FPL in EPIC. OCHC will review the SFS application on a 6-month basis. Additional processes were in place to simplify reporting for these accounts for follow up. Revenue Cycle Manager will complete reporting on a monthly basis. Account reconciliation will be handled by the Revenue Cycle Supervisor and billers.

Agencies: U.S. Department of Health and Human Services, State of Wisconsin Department of Health Services CFDA Number: 93.150 Program: Projects for Assistance in Transition from Homelessness Migrant Health Criteria: The Organization is required to have controls in place to monitor its subrecipient's compliance with the requirements of their grants and monitor its subrecipient's compliance with the program. Statement of condition: The Organization did not have adequate and effective controls over compliance in place as it relates to the monitoring of subrecipients. We found that the Organization was not performing site visits with the subrecipient agency and did not obtain audited financial statements in order to monitor that the subrecipient agency was using the awards in accordance with federal and state requirements. Questioned Costs: The amount of questioned costs could not be determined. Context: The Organization is required to monitor the compliance of the subrecipient agency's use of the federal and state awards. The Organization's policy is to complete site visits and obtain and review audited financial statements. The Organization did not perform either of these items in 2019. Effect: The Organization did not follow its policies to perform a site visit nor did it request and obtain other documentation from the subrecipient to verify compliance with federal and state requirements. Cause: Management has indicated that they relied only on trainings and reviewing monthly expenditure reporting from the subrecipient agency to monitor compliance. Recommendation: We recommend management adhere to their controls over compliance relating to the Organization's compliance of subrecipient monitoring to ensure that all requirements of the contract are being performed by the Organization and the subrecipients. Management's Response: As the lead agency, OCHC will conduct virtual or on-site chart and financial audits annually to monitor the sub recipient?s compliance. The chart audits will review and confirm program eligibility and data documentation.

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