HEALTH FIRST BLUEGRASSNon-Profit

Information on the federal program – Assistance Listing Number 93.224/93.527, Health Center Program Cluster from the U.S. Department of Health and Human Services, Federal Award No. 6 H80CS28202-09 for project period February 1, 2022 through January 31, 2025 Criteria or specific requirement – Health Centers must comply with federal reporting requirements Condition – The Health Center did not accurately complete its Federal Financial Report Cause – The detailed review of the submitted report missed the error of the line item. Effect or Potential Effect – The Federal Financial Report was submitted reported with incorrect data for lines 10 (l) – Total Federal share of program income earned Questioned Costs – Not applicable Context – Out of a population of 3 financial report required to be submitted during the year under audit, 1 financial report was tested. Identification as a repeat finding, if applicable – Not a repeat finding Recommendation – We recommend management continue to review the report and compare to other reports to help alleviate the error in the line item. Views of responsible officials and planned corrective actions – Management will continue their review process of the submitted reports.

Information on the federal program – Assistance Listing Number 93.224/93.527, Health Center Program Cluster from the U.S. Department of Health and Human Services, Federal Award No. 6 H80CS28202-09 for project period February 1, 2022 through January 31, 2025 Criteria or specific requirement – Special Tests and Provisions – 42 CFR, Part 56.303(e), (f), and (g). Health Centers receiving funds under the Health Center Program Cluster are required to prepare a schedule of fees or payments for the provision of its services designed to cover its reasonable costs of operation and a corresponding schedule of discounts adjusted on the basis of the patient’s ability to pay, to make every reasonable effort, including the establishment of systems for eligibility determination, billing and collection, and to secure from patient payments for services in accordance with the schedule of fees and discounts Condition – We noted during our testing of compliance with federal awards that the Health Center did not properly apply the sliding fee discounts approved by the board of directors for 4 out of a sample of 25 patients for the year ended December 31, 2024. Cause – Errors occurred when analyzing the patient account Effect or Potential Effect – Discounts were not properly applied to patient accounts based on the policy. Questioned Costs – Not applicable Context – From a total of 16,857 sliding fee discounts for the period, 25 discounts were selected for testing. This sample was not, and was not intended to be, a statistically valid sample. The Health Center’s management did prepare a schedule of discounts adjusted on the basis of the patient’s ability to pay; such schedule was periodically updated and approved by the Health Center’s board of directors and the schedule was uploaded into the Health Center’s billing system. However, there were errors when comparing the approved schedule to certain actual adjustments to patient accounts during the year ended December 31, 2024. For 1 of the 25 accounts selected for testing, the account had an incorrect discount applied and the 3 patients did not have supporting documentation (school based lunch application) to support the slide applied. Identification as a repeat finding, if applicable – Not a repeat finding Recommendation – We recommend management work to provide additional trainings to the staff responsible for completing sliding fee applications and those responsible for applying the sliding fee discount to patient accounts and conduct additional internal reviews to verify the patient accounts have been adjusted properly and appropriate supporting documentation is maintained in the patient’s file. Views of responsible officials and planned corrective actions – Management has begun staff training and will meet with the billing team regarding the sliding fee policy and process.

Provider Relief Fund; Federal Assistance Listing No. 93.498; U.S. Department of Health & Human Services Criteria or specific requirement: Reporting ? 45 CFR section 75.342. Condition: The Health Center is required to prepare and submit period three Provider Relief Fund (PRF) reporting using accurate financial information. Questioned cost: $0. Context: In the testing of the PRF report, the Health Center inadvertently inputted expenditures. Effect or potential effect: Potential errors may have been reported on the PRF report. Cause: The Health Center made a clerical error in reporting expenditures when the lost revenue was the source of use of the PRFs. Identification as a repeat finding, if applicable: Yes. Recommendation: We recommend management develop policies and procedures to compile and accurately report the information to ensure accurate reporting. Views of responsible officials and corrective actions: Management agrees with the finding and will update the report in the next reporting submission. Dan Becker, CFO, will work to reopen the period three report to update the financial information.

Provider Relief Fund; Federal Assistance Listing No. 93.498; U.S.Department of Health & Human Services Criteria or specific requirement: Reporting ? 45 CFR section 75.342 Condition: The Health Center is required to prepare and submit period one Provider Relief Fund (PRF) reporting using accurate financial information. Questioned cost: Unknown. Context: In the testing of the PRF report, the quarterly amounts reported on the PRF report were not supported by accurate underlying data. Effect or potential effect: Potential errors may have been reported on the annual PRF report. Cause: The Health Center was unable to produce accurate supporting financial information for the report submission. Identification as a repeat finding, if applicable: Not a repeat finding. Recommendation: We recommend management develop policies and procedures to compile and retain the information needed for reports to ensure accurate reporting. Views of Responsible Officials and Corrective Actions: Management agrees with the finding and will improve processes and maintaining of financial information which supports submitted reports. Dan Becker, CFO will work to reopen the period one report to update the financial information. The CFO will also maintain supporting documentation on the upcoming reporting periods.

Health Center Program Cluster; CFDA No. 93.224 and 93.527; U.S. Department of Health and Human Services; grant number H80CS28202; budget periods February 2, 2020, through January 31, 2021. Criteria or specific requirement: Special Tests and Provisions ? 42 CFR, Part 56.303(e), (f), and (g). Health Centers receiving funds under the Health Center Program Cluster are required to prepare a schedule of fees or payments for the provision of its services designed to cover its reasonable costs of operation and a corresponding schedule of discounts adjusted on the basis of the patient?s ability to pay, to make every reasonable effort, including the establishment of systems for eligibility determination, billing and collection, and to secure from patient payments for services in accordance with the schedule of fees and discounts. Condition: We noted during our testing of compliance with federal awards that the Health Center did not properly apply the sliding fee discounts approved by the board of directors for 4 patients out of a sample of 25 patients for the year ended December 31, 2020. Questioned cost: None Context: From a total of 14,717 sliding fee discounts for the period, 25 discounts were selected for testing. This sample was not, and was not intended, to be a statistically valid sample. The Health Center?s management did prepare a schedule of discounts adjusted on the basis of the patient?s ability to pay; such schedule was periodically updated and approved by the Health Center?s board of directors; and the schedule was uploaded into the Health Center?s billing system. However, there were errors when comparing the approved schedule to certain actual adjustments to patient accounts during the year ended December 31, 2020. For 4 of the 25 accounts selected for testing, the account had an incorrect discount applied. Effect: Discounts were not properly applied to patient accounts. Cause: The new sliding fee scales uploaded in the Health Center?s billing system does not automatically update patients? accounts who previously qualified for a different sliding fee adjustment class under the prior year?s scale, therefore patients could be charged more than required per the scale if they qualify for a lower slide category under updated federal poverty guidelines. Identification as a repeat finding, if applicable: Not a repeat finding Recommendation: We recommend management work with the billing system vendor to set up automatic updates to patient accounts based off the newly input sliding fee scales annually.