COMMUNITY MEDICAL WELLNESS CENTERS, USANon-Profit

2025-001 Sliding Fee Discount Determination CFDA Number: 93.224 Program: Community Health Center Cluster Agency: US Department of Health and Human Services Compliance Requirement: N Special Tests and Provisions Repeat Finding: Yes Criteria: Federal grant compliance provisions require that the Organization correctly identify a patient's ability to pay and that the rates for services be adjusted accordingly based on the sliding fee schedule. The Organization is required to follow its sliding fee policy when providing discounts to eligible patients. Finding/ Condition: In our sample of 40 tested items, incorrect sliding fee discounts were provided in 10 samples. Questioned Cost: None. Effect: Lack of strict enforcement of the policy of sliding fee eligibility determination and compliance may have resulted in the Organization providing discounted services greater to or less than the appropriate amounts to beneficiaries. Cause: Inadequate understanding of the sliding fee program requirements and Organization policies by employees involved in sliding fee determination and billing. Recommendation: Training should be provided to employees on the sliding fee program requirements. The Organization should perform regular audits of sliding fee transactions to identify weaknesses in compliance. Views of Responsible Officials and Corrective Action Plan: The Organization agrees with the finding and will implement additional controls to ensure that this does not recur. Please refer to the corrective action plan on page 35.

2025-002 Procurement Suspension and Debarment ALN: 93.224 Program: Community Health Center Cluster Agency: US Department of Health and Human Services Compliance Requirement: I Procurement Suspension and Debarment Repeat Finding: No Criteria: Per 45 CFR 75.327(i), a non-Federal entity who receives HHS awards must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Finding/Condition: During our testing of the Organization’s procurement transactions for federal purchases (25 samples), we noted the Organization could not provide a sufficient history of the procurement decisions including the method of procurement and contractor selection. Questioned Cost: None. Effect: The entity is not in compliance with 45 CFR 75.327 for procurement. Cause: The Organization did not have procedures in place for procurement in retaining the required documentation detailing the history of the procurement. Recommendation: We recommend the Organization develop procedures for procurement with federal funds. Views of Responsible Officials and Corrective Action Plan: The Organization will develop a system that maintains the required documentation for procurements in a centralized location. Please refer to the Corrective Action Plan on page 35.

2024-001 Sliding Fee Discount Determination CFDA Number: 93.224 Program: Community Health Center Cluster Agency: US Department of Health and Human Services Compliance Requirement: N- Special Tests and Provisions Repeat Finding: Yes Criteria: Federal grant compliance provisions require that the Organization correctly identify a patient's ability to pay and that the rates for services be adjusted accordingly based on the sliding fee schedule. The Organization is required to follow its sliding fee policy when providing discounts to eligible patients. Finding/ Condition: In our sample of 40 tested items, in multiple samples patient information was inadequate to determine the proper sliding fee discount. Questioned Cost: None. Effect: Lack of strict enforcement of the policy of sliding fee eligibility determination and compliance may have resulted in the Organization providing discounted services greater to or less than the appropriate amounts to beneficiaries. Cause: Inadequate understanding of the sliding fee program requirements and Organization policies by employees involved in sliding fee determination and billing. Recommendation: Training should be provided to employees on the sliding fee program requirements. The Organization should perform regular audits of sliding fee transactions to identify weaknesses in compliance. Views of Responsible Officials and Corrective Action Plan: The Organization agrees with the finding and will implement additional controls to ensure that this does not recur. Please refer to the corrective action plan on page 33.

Finding No.2023-001: Inaccurate Application of Sliding fee Discounts (Significant Deficiency) Assistance Listing Number: 93.829 Assistance Listing Program Title: Section 223 Demonstration Programs to Improve Community Mental Health Services. Federal Agency: Department of Health and Human Services (HHS) - Substance Abuse and Mental Health Services Administration (SAMHSA) Passed Through Entity: Not applicable Federal Award Number: 1H79SM085136-01 Federal Award Year: August 31, 2021 – August 30, 2023 Compliance Requirement: Special Tests and Provisions – Sliding Fee Discounts Criteria or Specific Requirements Health centers must have a schedule of fees or payments for the provision of their health services consistent with locally prevailing rates or charges and designed to cover their reasonable costs of operation. They are also required to have a corresponding schedule of discounts applied and adjusted based on the patient’s ability to pay. The patient’s ability to pay is determined based on the official poverty guidelines, as revised annually by the U.S. Department of Health and Human Services (HHS). The poverty guidelines are issued each year in the Federal Register and HHS maintains a web page that provides the poverty guidelines. Non-grant funds (State, local, and other operational funding and fees, premiums, and third-party reimbursements which the project may reasonably be expected to receive, including any such funds in excess of those originally expected), shall be used as permitted under the law and may be used for such other purposes as are not specifically prohibited under the law if such use furthers the objectives of the project. Condition The Organization determines the amount of fees to be charged to a patient based on the patient’s income, expense, and number of dependents in conjunction with the sliding fee schedule. Of the 25 patients selected for testing, we noted the following: - 4 patients were charged the incorrect sliding fee amount, which resulted in the Organization overcharging 2 patients by $10 each, while 2 patients were undercharged by $5 each. - 4 patients had no proof of income declaration and sliding fee application form on file. Due to an unsupported sliding fee discount, we were unable to determine if these 4 patients were eligible for the sliding fee and should have been charged the full amount totaling $523.48. Questioned Costs $513.48 in net undercharges for sliding fee patients sampled. Causes and Effect The potential cause for the above errors is as follows: - Error by staff in determining the patient’s ability to pay. - Lack of review and retention of sliding fee applications and income declaration forms. - Patients did not complete the required form necessary to determine the patient’s ability to pay. As a result, the determination of patient fees is not consistent with the sliding fee schedule. Recommendation We recommend that the Organization’s controls and procedures be strengthened to ensure 1) income declaration is properly verified and adequately documented and 2) the sliding fee discount is properly determined and applied. The Organization should also provide additional training to staff involved in the sliding fee process and ensure that appropriate individuals are properly monitoring and reviewing the Organization’s compliance with program requirements. This will help ensure that the proper sliding fee is charged to patients and that program goals and objectives are being met.

Criteria or Specific Requirement Health centers must have a schedule of fees or payments for the provision of their health services consistent with locally prevailing rates or charges and designed to cover their reasonable costs of operation. They are also required to have a corresponding schedule of discounts applied and adjusted based on the patient?s ability to pay. The patient?s ability to pay is determined based on the official poverty guidelines, as revised annually by HHS. The poverty guidelines are issued each year in the Federal Register and HHS maintains a web page that provides the poverty guidelines. Non-grant funds (State, local, and other operational funding and fees, premiums, and third-party reimbursements which the project may reasonably be expected to receive, including any such funds in excess of those originally expected), shall be used as permitted under the law and may be used for such other purposes as are not specifically prohibited under the law if such use furthers the objectives of the project. Condition The Organization determines the amount of fees to be charged to a patient based on the patient?s income, expense and number of dependents in conjunction with the sliding fee schedule. Of the 60 patients selected for testwork, we noted 14 patients that were charged the incorrect sliding fee amount, which resulted in the Organization overcharging 10 patients by $105, while 4 patients were undercharged by $105. Questioned Costs $0 in net charges for sliding fee patients sampled.The potential causes for the above errors are as follows: ? Error by staff in determining the patient?s ability to pay. ? Patients did not complete the required form necessary to determine patient?s ability to pay. As a result, the determination of patients fees are not consistent with the sliding fee schedule. Recommendation We recommend that the Organization?s controls and procedures be strengthened to ensure 1) income declaration is properly verified and adequately documented and 2) the sliding fee discount is properly determined and applied. The Organization should also provide additional training to staff involved in the sliding fee process and ensure that appropriate individuals are properly monitoring and reviewing the Organization?s compliance with program requirements. This will help ensure that the proper sliding fee is charged to patients and that program goals and objectives are being met.

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