EIN: 431036785
UEI: TMR8GAV35HH8
Audit also covers EIN: 431496431
Audited by: CohnReznick LLP
Oversight agency: 93 [Department of Health and Human Services]
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Data as of August 28, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on January 15, 2026. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by July 15, 2026 (46 days ago).
What is a management decision? →Finding 2025.002: Special tests and provisions – Sliding Fee Discounts – Significant Deficiency Grantor: U.S. Department of Health and Human Services Federal Program Names: 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 Federal Award Identification Number and Year: H8000133 - 2025 and 2024, H8L50678 - 2024, H8H46190 - 2023 and 2024 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)). PHC should be implementing and monitoring procedures to properly determine, calculate and review sliding fee discounts issued to patients in accordance with PHC's sliding fee scale. Condition PHC did not always calculate the proper sliding fee discount based on approved policies or have adequate documentation on file. Cause PHC did not have adequate internal controls in place to effectively ensure that patients received the correct sliding fee discount and have adequate documentation on file. Effect or Potential Effect PHC did not comply with the appropriate Special Tests and Provisions rules and regulations as per the Uniform Guidance in 2025. Questioned costs None. Context A test of 40 sliding fee discount transactions was performed and resulted in one instance of an incorrect sliding fee calculation, eight instances of inadequate documentation on file to support the sliding fee calculation and three instances of lack of review and approval. Our sample was a statistically valid sample. Identification of Repeat Finding This finding is a repeat finding (see prior year Finding 2024.001) Recommendation PHC should establish a system of internal controls to ensure that all sliding fee discounts are properly calculated and supported based on family size and income. Views of Responsible Officials Management agrees with the audit finding and will strengthen internal controls and accountability to correct the deficiency.
Show full finding ▾Hide full finding ▴Finding 2025.002: Special tests and provisions – Sliding Fee Discounts – Significant Deficiency Grantor: U.S. Department of Health and Human Services Federal Program Names: 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 Federal Award Identification Number and Year: H8000133 - 2025 and 2024, H8L50678 - 2024, H8H46190 - 2023 and 2024 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)). PHC should be implementing and monitoring procedures to properly determine, calculate and review sliding fee discounts issued to patients in accordance with PHC's sliding fee scale. Condition PHC did not always calculate the proper sliding fee discount based on approved policies or have adequate documentation on file. Cause PHC did not have adequate internal controls in place to effectively ensure that patients received the correct sliding fee discount and have adequate documentation on file. Effect or Potential Effect PHC did not comply with the appropriate Special Tests and Provisions rules and regulations as per the Uniform Guidance in 2025. Questioned costs None. Context A test of 40 sliding fee discount transactions was performed and resulted in one instance of an incorrect sliding fee calculation, eight instances of inadequate documentation on file to support the sliding fee calculation and three instances of lack of review and approval. Our sample was a statistically valid sample. Identification of Repeat Finding This finding is a repeat finding (see prior year Finding 2024.001) Recommendation PHC should establish a system of internal controls to ensure that all sliding fee discounts are properly calculated and supported based on family size and income. Views of Responsible Officials Management agrees with the audit finding and will strengthen internal controls and accountability to correct the deficiency.
Section III Federal Award Findings and Questioned Costs 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 Item 2025 002 Special Tests Recommendation The Center should establish a system of internal controls to ensure that all slide fee discounts are properly calculated based on family size and income. Repeat Finding Yes Action Taken The Finance Department will take the following steps to enhance the slide fee discounts process: 1. Policy Revision: the health center will revise its Sliding Fee Discount Policy to ensure alignment with HRSA requirements, including accurate discount calculation methodologies, annual updates to the sliding fee scale, and proper utilization of NextGen system functionality to support implementation 2. Staff Training: the health center will provide comprehensive training to all relevant staff on the revised Sliding Fee Discount Policy and procedures. 3. Training will emphasize correct discount calculations, required documentation, and income verification processes. A recurring training program will be implemented to ensure ongoing compliance for both new hires and existing employees. 3. Retrospective Review: the health center will conduct a retrospective review of patient files for the current fiscal year to confirm that all sliding fee discounts are appropriately supported by required documentation. Any identified discrepancies will be corrected in a timely manner. 4. Ongoing Monitoring: the health center will establish monthly internal audits of sliding fee discount determinations to monitor compliance. Audit results will be documented and reviewed by management to ensure corrective actions are taken as needed. Responsible Party: Chief Financial Officer Target Completion Date: 04/30/2026 If the Cognizant or Oversight Agency for Audit has questions regarding this plan, please call: Javier Vallejo, CFO at (314)-482-0915. Sincerely yours, Javier Vallejo Chief Financial Officer
2024-001
FAC accepted this audit on January 3, 2025 — management decision was due July 3, 2025.
Finding 2024.001: Special test and provisions – Sliding Fee Discounts – Significant Deficiency Grantor: U.S. Department of Health and Human Services Federal Program Names: Health Center Program Cluster Community Health Centers Affordable Care Act (ACA) Grants for New and Expanded Services Under the Health Center Program COVID-19 Affordable Care Act (ACA) Grants for New and Expanded Services Under the Health Center Program Federal Assistance Listing Numbers: 93.224 and 93.527 Federal Award Identification Number and Year: H8000133 – 2024 and 2023, C14CS39925 - 2021, H8G48629 – 2023, H8L50678 – 2024, H8H46190 - 2023 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 approved policies or have adequate documentation on file. Cause The Center did not have adequate internal controls in place to effectively ensure that patients received the correct sliding fee discount and have adequate documentation on file. Effect The Center did not comply with the appropriate Special Tests and Provisions rules and regulations as per the Uniform Guidance in 2024. Questioned costs None. Context A test of 40 slide fee discount transactions was performed and resulted in seven instances of a sliding fee discount not being properly calculated based on the respective patient family size and income or inadequate documentation being on file. Our sample was a statistically valid sample. Identification of Repeat Finding Yes Recommendation The Center should establish a system of internal controls to ensure that all slide fee discounts are properly calculated and supported based on family size and income. Views of Responsible Officials Management agrees with the audit finding and will strengthen internal controls and accountability to correct the deficiency.
Show full finding ▾Hide full finding ▴Finding 2024.001: Special test and provisions – Sliding Fee Discounts – Significant Deficiency Grantor: U.S. Department of Health and Human Services Federal Program Names: Health Center Program Cluster Community Health Centers Affordable Care Act (ACA) Grants for New and Expanded Services Under the Health Center Program COVID-19 Affordable Care Act (ACA) Grants for New and Expanded Services Under the Health Center Program Federal Assistance Listing Numbers: 93.224 and 93.527 Federal Award Identification Number and Year: H8000133 – 2024 and 2023, C14CS39925 - 2021, H8G48629 – 2023, H8L50678 – 2024, H8H46190 - 2023 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 approved policies or have adequate documentation on file. Cause The Center did not have adequate internal controls in place to effectively ensure that patients received the correct sliding fee discount and have adequate documentation on file. Effect The Center did not comply with the appropriate Special Tests and Provisions rules and regulations as per the Uniform Guidance in 2024. Questioned costs None. Context A test of 40 slide fee discount transactions was performed and resulted in seven instances of a sliding fee discount not being properly calculated based on the respective patient family size and income or inadequate documentation being on file. Our sample was a statistically valid sample. Identification of Repeat Finding Yes Recommendation The Center should establish a system of internal controls to ensure that all slide fee discounts are properly calculated and supported based on family size and income. Views of Responsible Officials Management agrees with the audit finding and will strengthen internal controls and accountability to correct the deficiency.
12/16/2024 United States Department of Health and Human Services Betty Jean Kerr – People’s Health Centers respectfully submits the following corrective action plan for the year ended May 31, 2024. CohnReznick LLP 350 Church Street Hartford, CT 06103 Audit Period: May 31, 2024 The findings from the May 31, 2024 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FEDERAL AWARDS FINDINGS AND QUESTIONED COSTS Section III‐ Federal Award Findings and Questioned Costs Community Health Centers, Affordable Care Act (ACA) Grants for New and Expanded Services Under the Health Center Program, COVID-19 Affordable Care Act (ACA) Grants for New and Expanded Services Under the Health Center Program Federal Assistance Listing Numbers: 93.224 and 93.527 Item 2024‐001 – Special Tests Recommendation The Center should establish a system of internal controls to ensure that all slide fee discounts are properly calculated based on family size and income. Repeat Finding Yes Action Taken 1. Upon notification of findings, new reporting structures and training were developed for the FOA staff. Direct governance was moved from finance to operations, and the scheduling supervisor was promoted to a newly created role entitled the Director of Patient Access. This role is directly responsible for training and the scheduling of FOA staff as well as data integrity of registration information. 2. Once developed, we provided targeted training sessions for all staff involved with the calculation of sliding fees on the policies and procedures to ensure: The sliding fee guidelines document is known. Understanding of the methodology for calculating fees, including how family size and income are considered. Documentation required to support income and family size information provided by clients. This may include tax returns, pay stubs, or other relevant documents. To use the standardized form (checklist) to ensure all necessary information is collected and verified. 3. We also have implemented a monthly audit process that randomly selects a sample of sliding fee patients. Selected patients’ files are reviewed to identify any potential discrepancies. If discrepancies are noted, prior to remediation, errors are documented so that thematic analysis can be conducted, and root causes can be identified. To ensure traction of the initiative, audit findings are presented monthly to the quality assurance and performance improvement committee. 4. We make every effort we can to effectively communicate the sliding fee scale to clients. In addition to face-to-face communication, it is presented openly in several locations throughout the agency and is also available on our website. We are aware that ensuring the continued compliance of the SFS scale determinations, as well as the financial accuracy of our books requires consistent and continuous commitment to quality and improvement. We are confident that the changes made to our internal controls will significantly strengthen our processes. We believe these measures will mitigate the risk of errors and inaccuracies in the future, providing greater assurance over the reliability of our financial reporting. If the Cognizant or Oversight Agency for Audit has questions regarding this plan, please call: Javier Vallejo, CFO at 314-482-0915. Sincerely yours, Javier Vallejo Chief Financial Officer
2023-002
FAC accepted this audit on February 28, 2024 — management decision was due August 28, 2024.
Finding 2023-002: Grantor: Federal Program Names: Sliding Fee Scale Documentation U.S. Department of Health and Human Services 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 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. Context A test of 40 slide fee discount transactions was performed and resulted in one 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. Cause The Center did not have adequate internal controls in place to effectively ensure that all sliding fee discounts were properly calculated based on approved documentation. Effect The Center did not comply with the appropriate rules and regulations as per the Uniform Guidance. Questions costs None. Identification of Repeat Finding Yes Recommendation The Center should establish a system of internal controls to ensure that all sliding fee discounts are properly calculated based on family size and income. Views of Responsible Officials Management agrees with the audit finding and will strengthen internal controls and accountability to correct the deficiency.
Show full finding ▾Hide full finding ▴Finding 2023-002: Grantor: Federal Program Names: Sliding Fee Scale Documentation U.S. Department of Health and Human Services 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 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. Context A test of 40 slide fee discount transactions was performed and resulted in one 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. Cause The Center did not have adequate internal controls in place to effectively ensure that all sliding fee discounts were properly calculated based on approved documentation. Effect The Center did not comply with the appropriate rules and regulations as per the Uniform Guidance. Questions costs None. Identification of Repeat Finding Yes Recommendation The Center should establish a system of internal controls to ensure that all sliding fee discounts are properly calculated based on family size and income. Views of Responsible Officials Management agrees with the audit finding and will strengthen internal controls and accountability to correct the deficiency.
Item 2023-002 - Special Tests Recommendation The Center should establish a system of internal controls to ensure that all sliding fee discounts are properly calculated based on family size and income. Repeat Finding Yes Action Taken 1. To train all staff involved with the calculation of sliding fees on the policies and procedures to ensure: ► The sliding fee guidelines document is known. ► Understanding of the methodology for calculating fees, including how family size and income are considered. ► Documentation required to support income and family size information provided by clients. This may include tax returns, pay stubs, or other relevant documents. ► To use the standardized form (checklist) to ensure all necessary information is collected and verified. 2. To perform a monthly audit review, utilizing a selected sample to identify any discrepancies and make necessary corrections in a timely manner. 3. To ensure the sliding fee scale is clearly communicated to clients. Responsible Party: Director of Patient Services/RCM Director Target Completion Date: 04/30/2024 If the Cognizant or Oversight Agency for Audit has questions regarding this plan, please call: Hewart Tillett, CFO at 1-314-882-1463, or email at htillett@phcenters.com.
2022-001
FAC accepted this audit on April 18, 2023 — management decision was due October 18, 2023.
U.S. Department of Health and Human Services, COVID-19 - Health Center Program Cluster (Assistance Listing Number 93.224/93.527) Item 2022-002 ? Special Tests and Provisions 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 family size and income. Condition The Center did not always appropriately apply the sliding fee discount based on income levels and family size. Context A test of 40 discount transactions was performed and resulted in three instances of sliding fee discounts not being properly calculated based on the respective patient family size and income. Our sample was a statistically valid sample. Cause The Center did not have adequate internal controls in place to effectively ensure that patients receive the correct sliding fee discount. Effect The Center did not comply with the appropriate rules and regulations as per the Uniform Guidance. Questioned Costs None Identification of Repeat Finding Yes ? 2021-004 Recommendation The Center should ensure that internal controls are in place to effectively ensure that patients receive the correct sliding fee discount. View of Responsible Officials Management and the Board of Directors agree with the finding.
Show full finding ▾Hide full finding ▴U.S. Department of Health and Human Services, COVID-19 - Health Center Program Cluster (Assistance Listing Number 93.224/93.527) Item 2022-002 ? Special Tests and Provisions 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 family size and income. Condition The Center did not always appropriately apply the sliding fee discount based on income levels and family size. Context A test of 40 discount transactions was performed and resulted in three instances of sliding fee discounts not being properly calculated based on the respective patient family size and income. Our sample was a statistically valid sample. Cause The Center did not have adequate internal controls in place to effectively ensure that patients receive the correct sliding fee discount. Effect The Center did not comply with the appropriate rules and regulations as per the Uniform Guidance. Questioned Costs None Identification of Repeat Finding Yes ? 2021-004 Recommendation The Center should ensure that internal controls are in place to effectively ensure that patients receive the correct sliding fee discount. View of Responsible Officials Management and the Board of Directors agree with the finding.
April 4, 2023, Betty Jean Kerr- People's Health Centers respectfully submits the following corrective action plan for the year ended May 31, 2022. CohnReznick, LLP 350 Church Street Hartford, CT 06103 Audit Period: May 31, 2022 Section II- Financial Statement Findings: Item 2022-001- Financial Reporting Recommendation We recommend that the Center ensure that the monthly financial statement close process is being performed in a timely and accurate manner. Action Taken: 1. Review Monthly Closing checklist to it is complete and save as Master Monthly Closing Listing on Shared Drive and is shared electronically and by paper to all accounting team members. The Closing listing will address all the activities before closing accounting records for the month. The focus should be: - ensure whether maintain a "Manual GL Entry List" to list down those commonly recurring GL entries together with preparer and reviewer. - determining what supporting files are required, and responsibility of related teams (billing, management, etc). - determining suggested completion day to ensure the completeness of GL entry during closing. 2. The closing checklist reviewed will be shared by Finance Controller and/or delegated role in a timely manner no later than 7 days before month end. Responsible Party: Director of Finance Completion Date: June 30,2022. Prior year audit FY2021 (06/01/2020 - 05/31/2021) was completed late by BKD, in May of 2022, the corrective action plan was implemented in June of 2022. Therefore, this finding was required for in FY2022 (06/01/2021- 05/31/2022} as well. Section Ill- Federal Award Findings and Questioned Costs U.S. Department of Health and Human Services, COVID-19 - Health Center Program Cluster (Assistance Listing Number 93.224/93.527) Item 2022-002 - Special Tests and Provisions Recommendation The Center should ensure that internal controls are in place to effectively ensure that patients receive the correct sliding fee discount. Action Taken: 1. To fix the system, so that the co-pay will roll up to the encounter and not by line item. 2. To implement at least twice an annual review to check & confirm the sliding fees in current program and billing system are consistent. 3. To implement a monthly sliding fee review, based on a sample selected to ensure the sliding fee was appropriately applied and it is according to the policy. Until we hire a Sliding Fee Specialist, the RCM Director will conduct the monthly review. And, following staff hiring, RCM Director will do routine samplings to ensure accuracy. 4. To update the Sliding Fee Guidelines document and communicate/re-train all employees involved in the process. 5. For the sliding fee patients with date of service 6.1.2020 to 12.31.2021, a report was run to capture all those patients, the billing department is working a special project to review and adjust if needed any encounter showing more than one co-pay per visit. This report is being monitored closely. Responsible Party: RCM Director Target Completion Date: June 30, 2022. Prior year audit FY2021 (06/01/2020 - 05/31/2021) was completed late by BKD, in May of 2022, the corrective action plan was implemented in June of 2022. Therefore, this finding was required for in FY2022 {06/01/2021- 05/31/2022) as well. If the Cognizant or Oversight Agency for the Audit has questions regarding this plan, please call: Rebecca Mankin, CFO at (660) 223-6212. Rebecca Mankin Chief Financial Officer
2021-004
FAC accepted this audit on May 2, 2022 — management decision was due November 2, 2022.
Finding ? Special Tests and Provisions. Federal Program ? Health Center Program Cluster, Assistance Listing Number #93.224 and #93.527 U.S. Department of Health and Human Services - Bureau of Primary Health Care Community Health Centers Grant and Affordable Care Act - Grants for Net and Expanded Services under the Health Center Program. Award Numbers H80CS00133-20-00 and H80CS00133-20-01, Award Year 2021 and 2022. Community Health Centers/Capital Assistance for Disaster Response and Recovery Efforts, Award Number - C14CS39925, Award Year 2021 Community Health Centers/COVID-19 Expanding Capacity for Coronavirus Testing, Award Number - H8ECS38034, Award Year 2021 Community Health Centers/COVID-19 Supplemental Funding, Award Number - H8CCS34711-01-00, Award Year 2021 Community Health Centers/COVID-19 CARES Act, Award Number - H8DCS35931-01-00, Award Year 2021 Community Health Centers/American Rescue Plan, Award Number - H8FCS41313-01-00, Award Year 2023 Criteria or Specific Requirement ? Health centers must prepare and apply a sliding fee discount schedule that incorporates the provisions of 42CFR 51c.303e through 56.303g to ensure that amounts owed for health center services by eligible patients are adjusted (discounted) based on the patient's ability to pay. Condition ? Certain encounters were not applied the proper co-pay. In certain instances where patients received multiple services from the Center, co-pays were applied for each service. This is not in line with the Center?s sliding fee policy. Questioned Costs ? None Context ? Out of a population of 4,473 encounters with sliding fees applied, a sample of 40 were tested. Of the 40 encounters selected, 14 did not have the proper sliding fee applied. A non-statistical sampling methodology was used to select the sample. Effect ? The sliding fee was not appropriately applied on certain encounters based on the Center?s sliding fee policy. This resulted in some patients being under-charged based on the Center?s policy. Cause ?The sliding fees were not applied appropriately due to inappropriate inputs in the Center?s system and lack of appropriate management review controls in place. Identification of a Repeat Finding ? N/A Recommendation ? We recommend that the Center implement regular reviews of its system to ensure the appropriate settings are maintained within its billing system. Additionally, we recommend that a member of management with an understanding of the Center?s billing and sliding fee policies regularly review a sample of sliding fees in comparison to the Center?s sliding fee policy. Views of responsible officials and planned corrective actions ? The Company agrees with the finding. See separate auditee document for planned corrective action.
Show full finding ▾Hide full finding ▴Finding ? Special Tests and Provisions. Federal Program ? Health Center Program Cluster, Assistance Listing Number #93.224 and #93.527 U.S. Department of Health and Human Services - Bureau of Primary Health Care Community Health Centers Grant and Affordable Care Act - Grants for Net and Expanded Services under the Health Center Program. Award Numbers H80CS00133-20-00 and H80CS00133-20-01, Award Year 2021 and 2022. Community Health Centers/Capital Assistance for Disaster Response and Recovery Efforts, Award Number - C14CS39925, Award Year 2021 Community Health Centers/COVID-19 Expanding Capacity for Coronavirus Testing, Award Number - H8ECS38034, Award Year 2021 Community Health Centers/COVID-19 Supplemental Funding, Award Number - H8CCS34711-01-00, Award Year 2021 Community Health Centers/COVID-19 CARES Act, Award Number - H8DCS35931-01-00, Award Year 2021 Community Health Centers/American Rescue Plan, Award Number - H8FCS41313-01-00, Award Year 2023 Criteria or Specific Requirement ? Health centers must prepare and apply a sliding fee discount schedule that incorporates the provisions of 42CFR 51c.303e through 56.303g to ensure that amounts owed for health center services by eligible patients are adjusted (discounted) based on the patient's ability to pay. Condition ? Certain encounters were not applied the proper co-pay. In certain instances where patients received multiple services from the Center, co-pays were applied for each service. This is not in line with the Center?s sliding fee policy. Questioned Costs ? None Context ? Out of a population of 4,473 encounters with sliding fees applied, a sample of 40 were tested. Of the 40 encounters selected, 14 did not have the proper sliding fee applied. A non-statistical sampling methodology was used to select the sample. Effect ? The sliding fee was not appropriately applied on certain encounters based on the Center?s sliding fee policy. This resulted in some patients being under-charged based on the Center?s policy. Cause ?The sliding fees were not applied appropriately due to inappropriate inputs in the Center?s system and lack of appropriate management review controls in place. Identification of a Repeat Finding ? N/A Recommendation ? We recommend that the Center implement regular reviews of its system to ensure the appropriate settings are maintained within its billing system. Additionally, we recommend that a member of management with an understanding of the Center?s billing and sliding fee policies regularly review a sample of sliding fees in comparison to the Center?s sliding fee policy. Views of responsible officials and planned corrective actions ? The Company agrees with the finding. See separate auditee document for planned corrective action.
Action Plan 1. To fix the system, so that the co-pay will roll up to the encounter and not by line item. 2. To implement at least twice annual review to check & confirm the sliding fees in current program and billing system are consistent. 3. To implement a monthly sliding fee review, based on a sample selected to ensure the sliding fee was appropriately applied and it is according to the policy. Until we hire a Sliding Fee Specialist, the RCM Director will conduct the monthly review. And, following staff hiring, RCM Director will do routine samplings to ensure accuracy. 4. To update the Sliding Fee Guidelines document and communicate/re-train all employees involve in the process. 5. For the sliding fee patients with date of service 6.1.2020 to 12.31.2021, a report was run to capture all those patients, the billing department is working a special project to review and adjust if needed any encounter showing more than one co-pay per visit. This report is being monitored closely. Responsible Party: RCM Director Target Completion Date: June 30, 2022
FAC accepted this audit on April 18, 2021 — management decision was due October 18, 2021.
FAC accepted this audit on March 4, 2020 — management decision was due September 4, 2020.
FAC accepted this audit on March 8, 2019 — management decision was due September 8, 2019.
FAC accepted this audit on November 15, 2017 — management decision was due May 15, 2018.
FAC accepted this audit on February 26, 2017 — management decision was due August 26, 2017.
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