AIDS ACTION COALITION OF HUNTSVILLE AND SUBSIDIARYNon-Profit

Health Center Program Cluster – CFDA Nos. 93.224 and 93.527 U.S. Department of Health and Human Services Award No. 5 H80CS33642-05-00 Program Year 2023 Criteria or Specific Requirement – Special Tests and Provisions: Sliding Fee Discounts (42 USC 254(k)(3)(g); 42 CFR sections 51c.303(g); and 42 CFR sections 56.303 (f)) Condition – Patients received a sliding fee discount that was inconsistent with the stated sliding fee discount categories under the Organization’s policy. Questioned cost – None Context – A sample of 40 patients out of 16,516 encounters were tested and 4 errors were noted where patients received an incorrect sliding fee adjustment. The sampling methodology used is not and is not intended to be statistically valid. Four patients received a sliding fee adjustment that was inconsistent with the approved policy for the proper sliding fee adjustments based on their income documentation. Effect – Sliding fee discounts were given to patients that were inconsistent with the Organization’s sliding fee discount policy. Cause – The Organization did not comply with their sliding fee policy. Identification as a repeat finding, if applicable – Is a repeat finding of 2022-001. Recommendation – We recommend management continue to ensure all personnel understand the sliding fee scale policy and adhere to the requirements and guidelines set forth in the policy. Procedures should be implemented to ensure that eligible patients receive discounts in accordance with the sliding fee scale and the Health Center Program Compliance Manual.

Health Center Program Cluster ? CFDA Nos. 93.224 and 93.527 U.S. Department of Health and Human Services Award No. 2 H80CS33642-04-00 Program Year 2022 Criteria or Specific Requirement ? Special Tests and Provisions: Sliding Fee Discounts (42 USC 254(k)(3)(g); 42 CFR sections 51c.303(g); and 42 CFR sections 56.303 (f)) Condition ? Patients received a sliding fee discount that was inconsistent with the stated sliding fee discount categories under the Organization?s policy. Questioned cost ? None Context ? A sample of 40 patients were tested and 2 errors were noted where patients received an incorrect sliding fee adjustment. The sampling methodology used is not and is not intended to be statistically valid. Two patients received a sliding fee adjustment that was inconsistent with the approved policy for the proper sliding fee adjustments based on their income documentation. Effect ? Sliding fee discounts were given to patients that were inconsistent with the Organization?s sliding fee discount policy. Cause ? The Organization did not comply with their sliding fee policy. Identification as a repeat finding, if applicable ? Is a repeat finding of 2021-001. Recommendation ? We recommend management continue to ensure all personnel understand the sliding fee scale policy and adhere to the requirements and guidelines set forth in the policy. Procedures should be implemented to ensure that eligible patients receive discounts in accordance with the sliding fee scale and the Health Center Program Compliance Manual. Views of Responsible Officials and Planned Corrective Actions - In order to ensure the Sliding Fee discounts are consistently calculated and applied to patients? accounts, Thrive changed the EMR set up to increase automation in September 2021, which reduced manual transactions and potential Slide Fee errors. Thrive continues to review and have discussions of the Sliding Fee policy and procedures with the outsourced billing company who are aware of, and understand, and are following them to the best of their abilities. Beginning in January 2023, the billing company began monitoring the creator of and the accuracy of slide adjustments. This will be done by running a report of slide adjustments in the month and spot checking 20-30 accounts for accuracy. Comments will be made on the monthly list and saved. Any concerns will be investigated. Other procedures already in place to monitor sliding fee discounts include monthly audits which began September 2021. These audits are conducted by Carmen Fortson, Director of Patient Access and Natoris Harris Patient Access Manager. This year they audit 5 charts per provider and will increase that by choosing another 5 charts at random for additional testing. They review the sample for sliding fee discounts applied to them, the correct insurance information, documentation of proof of income, and correct Federal Poverty Limit designation, and discount calculations. Any discrepancies are investigated and providers and management are educated in best practices. The monthly review also includes an internal audit of client records to identify any patients that have provided the proper proof of income qualify for the sliding fee discount that are not receiving the discount. If this situation occurs, training will be conducted by Carmen or Natoris with their staff to ensure the patients who are qualified are receiving the discounts.

Health Center Program Cluster ? CFDA Nos. 93.224 and 93.527 U.S. Department of Health and Human Services Award No. 5 H80CS33642-03-03 Program Year 2021 Criteria or Specific Requirement ? Special Tests and Provisions: Sliding Fee Discounts (42 USC 254(k)(3)(g); 42 CFR sections 51c.303(g); and 42 CFR sections 56.303 (f)) Condition ? Patients received a sliding fee discount that was inconsistent with the stated sliding fee discount categories under the Organization?s policy. Questioned cost ? None Context ? A sample of 40 patients were tested out of the total population of 16,459 encounters. The sampling methodology used is not and is not intended to be statistically valid. Six patients received a sliding fee adjustment that was inconsistent with the approved policy for the proper sliding fee adjustments based on their income documentation. Effect ? Sliding fee discounts were given to patients that were inconsistent with the Organization?s sliding fee discount policy. Cause ? The Organization did not comply with their sliding fee policy. Identification as a repeat finding, if applicable ? Is a repeat finding of 2020-001. Recommendation ? We recommend management continue to ensure all personnel understand the sliding fee scale policy and adhere to the requirements and guidelines set forth in the policy. Procedures should be implemented to ensure that eligible patients receive discounts in accordance with the sliding fee scale and the Health Center Program Compliance Manual. Views of Responsible Officials and Planned Corrective Actions ? In order to ensure the Sliding Fee discounts are consistently calculated and applied to patients' accounts, Thrive has (a) completed the change in the EMR set up to increase automation in September 2021, reducing manual transactions and potential Slide Fee errors; (b) completed reviews and discussions of the Sliding Fee policy and procedures with the outsourced billing company who are aware of, and understand, and are following them to the best of their abilities; and (c) continued with the procedures already in place to monitor sliding fee discounts. Carmen Fortson, Director of Patient Access and Natoris Harris Patient Access Manager continue to conduct monthly audits which began September 2021. They audit by selecting 5 charts per provider with sliding fee discounts applied to them. They review the sample for correct insurance information, documentation of proof of income, and correct Federal Poverty Limit designation, and discount calculations. Any discrepancies are investigated and providers and management are educated in best practices. The monthly review also includes an internal audit of client records to identify any patients that have provided the proper proof of income qualify for the sliding fee discount that are not receiving the discount. If this situation occurs, training will be conducted by Carmen or Natoris with their staff to ensure the patients who are qualified are receiving the discounts.

Health Center Program Cluster ? Assistance Listing Nos. 93.224 and 93.527 U.S. Department of Health and Human Services Award No. 5 H80CS33642-03-03 Program Year 2021 Substance Abuse and Mental Health Services Projects of Regional and National Significance ? Assistance Listing No. 93.243 Awards 5H79SP021835-05 and 5H79T1080631-04 Program Year 2021 Criteria or Specific Requirement ? Procurement ? 45 CFR 75.329 Condition ? The Organization did not follow its policy governing procurement requirements for the purchase of goods or services charged to federal awards. Questioned cost ? None Context ? A sample of three procurements were tested out of a population of twenty-two procurements totaling $743,052. The sample was not, and is not intended to be, statistically valid. Of the three procurements, two procurements in the amount of $107,072 did not follow the Organization?s procurement policy for vendor selection. Effect ? Purchases were made that did not adhere to the Organization?s procurement policy. Cause ? The Organization did not comply with their federal procurement policy. Identification as a repeat finding, if applicable ? Is not a repeat finding. Recommendation ? The Organization should review its procurement policy and ensure proper staff education on the policy is established. In addition, the Organization should review the policy on an annual basis to ensure it is consistent with Uniform Guidance. Views of Responsible Officials and Planned Corrective Actions ? To be sure we are following Thrive's written Procurement policy, Kim Croft, the Procurement Specialist, is developing a checklist to be followed and initiated by her department. The checklist will indicate the required number of bids to be received before renewal or original request will be considered for approval. It will contain guidance for price analyses, bids, and to include a memo if a sole source bid or vendor was used. Once completed in March 2022 the checklist will be kept with the contract, lease agreement, or invoice as appropriate.

Health Center Program Cluster ? CFDA Nos. 93.224 and 93.527 U.S. Department of Health and Human Services Award No. 6 H80CS33642-02-05 Program Year 2020 Criteria or Specific Requirement ? Special Tests and Provisions: Sliding Fee Discounts (42 USC 254(k)(3)(g); 42 CFR sections 51c.303(g); and 42 CFR sections 56.303 (f)) Condition ? Patients received a sliding fee discount that was inconsistent with the stated sliding fee discount categories under the Organization?s policy. Questioned cost ? None Context ? A sample of 25 patients were tested out of the total population of 13,024 encounters. The sampling methodology used is not and is not intended to be statistically valid. Eight patients received a sliding fee adjustment that was inconsistent with the approved policy for the proper sliding fee adjustments based on their income documentation. Effect ? Sliding fee discounts were given to patients that were inconsistent with the Organization?s sliding fee discount policy. Cause ? The Organization did not comply with their sliding fee policy. Identification as a repeat finding, if applicable ? Is not a repeat finding. Recommendation ? We recommend management continue to ensure all personnel understand the sliding fee scale policy and adhere to the requirements and guidelines set forth in the policy. Procedures should be implemented to ensure that eligible patients receive discounts in accordance with the sliding fee scale and the Health Center Program Compliance Manual. Views of Responsible Officials and Planned Corrective Actions ? Management recognizes the importance of preparing financial statements that are materially correct in accordance with accounting principles generally accepted in the United States of America (GAAP). In order to ensure our sliding fee discounts are consistently calculated and applied to patients? accounts, Thrive has put procedures in place to monitor sliding fee discounts. Carmen Fortson, Patient Access Coordinator, and Natoris Harris, Patient Access Lead, will conduct monthly audits of the sliding fee discounts beginning February 2021 by selecting 10 charts per provider with sliding fee discounts applied to them. They will review the sample for correct insurance information, documentation of proof of income, and correct Federal Poverty Limit designation. Any discrepancies will be investigated to ensure they aren?t happening on a larger scale and any issues found through these investigations will be communicated to the providers and management. In addition, internal audits of client records will be performed to identify any patients that have provided the proper proof of income qualify for the sliding fee discount that are not receiving the discount. In situations like this, remedial training will be done by Carmen or Natoris with their staff to ensure the patients who are qualified are receiving the discounts.