NO/AIDS Task Force D/B/A CrescentCare

Federal Organization: U.S Department of Health and Human Services Assistance Listing Numbers: 93.224 & 93.527 Health Center Program Cluster Award Numbers: H80CS26583, H8FCS41666 Criteria : Compliance Finding Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart F, Compliance Supplement, Part 4, Compliance Requirement N, Special Tests and Provisions states, “Health Centers must prepare and apply a sliding fee discount schedule so that the amounts owed for health center services by eligible patients are adjusted (discounted) based on the patients ability to pay.” Condition: During our testing of sliding fee discounts for health center patients qualifying for reduced charge visits, we identified one incident where the slide fee was applied to a patient account without a completed application on file and three incidents in which the incorrect sliding fee was applied. Context: This finding appears to be a systemic incident. A sample size of 25 patients included one without an application on file and three which did not have the correct sliding fee applied. Cause:The Organization did not follow its policies and procedures set in place to ensure the sliding fee schedule discount is correctly determined and applied to patient accounts. Effect: Patients may have been granted the incorrect sliding fee discount Questioned Costs: There were no questioned costs identified Recommendation: We recommend continued effort in training personnel to be properly trained on applying the appropriate sliding fee discount based on the Organization’s approved policy and in compliance with the OMB Compliance Supplement requirements. An appropriate level of review should be conducted on patient accounts to ensure proper document retention, application of sliding fee discounts, and third-party insurance billing. Views of Responsible Officials and Planned Corrective Action: CrescentCare agrees with the finding and has put staff and procedures in place to prevent these incidents from occurring.

The Clinical Practice Director has put procedures in place to verify the accuracy of documentation and application of the correct slide. The procedures consist of a monthly review of the paperwork and sliding fee for completeness and accuracy and continued training of personnel.

2022-002

2022-002 Application of Sliding Fee Discount Program Information Federal Organization U.S Department of Health and Human Services Assistance Listing Numbers 93.224 & 93.527 Health Center Program Cluster Award Numbers H80CS26583, H8FCS41666 Criteria [X] Compliance Finding [ ] Significant Deficiency [ ] Material Weakness Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart F, Compliance Supplement, Part 4, Compliance Requirement N, Special Tests and Provisions states, ?Health Centers must prepare and apply a sliding fee discount schedule so that the amounts owed for health center services by eligible patients are adjusted (discounted) based on the patients ability to pay.? Condition During our testing of sliding fee discounts for health center patients qualifying for reduced charge visits, we identified two incidents in which the incorrect sliding fee was applied. Context This finding appears to be an isolated incident. A sample size of 25 patients included two which did not have the correct sliding fee applied. Cause The Organization did not follow its policies and procedures set in place to ensure the sliding fee schedule discount is correctly determined and applied to patient accounts. Effect Patients may have been granted the incorrect sliding fee discount. Questioned Costs None identified Recommendation We recommend continued effort in training personnel to be properly trained on applying the appropriate sliding fee discount based on the Organization?s approved policy and in compliance with the OMB Compliance Supplement requirements. An appropriate level of review should be conducted on patient accounts to ensure proper document retention, application of sliding fee discounts, and third-party insurance billing. Views of responsible officials and planned corrective action CrescentCare agrees with the finding and will train and retrain staff on correct implementation of the sliding fee scale. Management supports continued training of staff on applying the appropriate sliding fee discount.

2022-002 Application of Sliding Fee Discount Corrective action planned: Management conducts quarterly internal audits of sliding fee discounts for health center patients. Based on the audit finding and the results of the internal audit, additional training and retraining will be provided to the personnel to support the correct application of the sliding fee discount program. Anticipated completion date: Ongoing Contact person responsible for corrective action: Roxanne Hadnott-Songy, Director of Compliance

Federal agency: U.S. Department of Housing and Urban Development Federal program title: Housing Opportunities for Persons with AIDS (HOPWA) CFDA Number: 14.241 Pass-Through Agency: City of New Orleans Division of Housing and Neighborhood Development Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: A person eligible for assistance under this program means a person with HIV or AIDS who is a low-income individual and the person?s family, including persons important to their care or well-being, as defined in 24 CFR section 574.3. The eligibility of those tenants who were admitted to the program should be determined by (1) obtaining applications that contain all the information needed to determine eligibility, including diagnosis, documentation of housing need, income, rent, and order of selection; and (2) obtaining third-party verifications or documentation of expected income, assets, unusual medical expenses, and any other pertinent information. Condition: One program participant was miscoded to HOPWA instead of the program they were noted to be eligible for, which was CFDA 14.267, Continuum of Care. Context: One out of 60 tenants tested was improperly coded to HOPWA instead of Continuum of Care, with a monthly rent payment of $623. It was noted that no other months were coded to HOPWA for this participant in our testing. Questioned Costs: $623 Cause: There was a coding error for the tenant. Effect: Tenant was coded to program for which eligibility requirements were not met. Recommendation: We recommend CrescentCare implement controls around participants entering program to ensure proper program utilized. Views of responsible officials: We have implemented additional workflows and internal reviews to ensure that individuals are coded and billed to the correct program. The check in question did not actually clear the bank prior to submitting the final invoice, therefore we did not actually receive reimbursement from the HOPWA funds for this questioned cost.

U.S. Department of Housing and Urban Development 2020-003 Housing Opportunities for Persons with AIDS (HOPWA) ? CFDA No. 14.241 Recommendation: We recommend CrescentCare implement controls around participants entering program to ensure proper program utilized. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We have implemented additional workflows and internal reviews to ensure that individuals are coded and billed to the correct program. We have hired one additional staff member and are in the process of expanding the role of another staff member to assist with the oversite of this program. Name(s) of the contact person(s) responsible for corrective action: Andre Duhe Planned completion date for corrective action plan: January 31, 2021.

Federal agency: U.S. Department of Health and Human Services Federal program title: Health Center Program CFDA Number: 93.224 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: Health centers must prepare and apply a sliding fee discount schedule so that the amounts owed for health center services by eligible patients are adjusted (discounted) based on the patient?s ability to pay based on Federal Poverty Guidelines. Condition: During our testing surrounding the sliding fee discount policy, we noted two sliding fee adjustments were calculated incorrectly. In both scenarios, the system included incorrect information compared to the sliding fee application and other support on file. Context: Out of 40 patients tested, we noted errors on these two patients. The system included two dependents for the first patient when the sliding fee application only listed one dependent. The sliding fee application for the second patient included two different financial amounts which would have conflicting sliding fee adjustments. This difference was not investigated prior to being input in the system. Cause: Manual error in data entry. Effect: The patient paid an incorrect amount for their sliding fee. Recommendation: We recommend the organization have a review process over the data entry to ensure accuracy and provide training as needed to mitigate risk of future errors. Views of responsible officials We have recently hired a new Practice Registration Manager and she is in the process of revising the sliding fee schedule SOP and updating the training process for staff. The revised SOP includes another layer of review prior to applying the sliding fee schedule in our electronic health record as well as auditing for the correct application.

U.S. Department of Health and Human Services 2020-008 Health Center Program ? CFDA 93.224 Recommendation: We recommend the organization have a review process over the data entry to ensure accuracy and provide training as needed to mitigate risk of future errors. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We have recently hired a new Practice Registration Manager and she is in the process of revising the sliding fee schedule SOP and updating the training process for staff. The revised SOP includes another layer of review prior to applying the sliding fee schedule in our health record as well as auditing for the correct application. Name(s) of the contact person(s) responsible for corrective action: Andre Duhe Planned completion date for corrective action plan: March 30, 2021.

Federal agency: U.S. Department of Housing and Urban Development Federal program titles: Housing Opportunities for Persons with AIDS and Continuum of Care CFDA Numbers: 14.241 and 14.267 Pass-Through Agencies: City of New Orleans Division of Housing and Neighborhood Development, Unity of Greater New Orleans Type of Finding: Material Weakness in Internal Control over Compliance Criteria or specific requirement: For CFDA 14.267: 24 CFR section 578.49(b)(1) and 578.49(b)(2) and 578.51(g). For CFDA 14.241: 24 CFR section 574.320. These standards require that rents paid must be reasonable in relation to rents being charged in the area for comparable space. CrescentCare prepares a rent reasonableness checklist and certification form which documents the rent reasonableness of the unit. The form is signed and dated by the person who completed the calculation. For some of the checklists reviewed, we noted that there was no evidence of the date the reasonableness testing was completed. It was unclear if the form was completed prior to rent payments beginning as there was no date. We noted in all forms that rent was determined to be reasonable. Context: For CFDA 14.241, 14 of the 40 checklists we tested did not contain evidence of the date the form was completed. For CFDA 14.267, 15 of the 19 checklists we tested did not contain evidence of the date the form was completed. Cause: The person who prepared the form missed the date field when completing. Effect: If the form is not prepared prior to rent payments beginning, excessive rent could be paid. Recommendation: We recommend CrescentCare train its employees on the forms to ensure that the date field is completed, and that forms are in tenant files prior to rent payments beginning. Views of responsible officials: Management will develop a process to ensure that all rent reasonableness forms are dated, signed and retained in the file when completed. Management notes that these forms are completed and filed electronically which the date of completion could be verified by the date the form was uploaded to the system.

U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT Housing Opportunities for Persons with AIDS and Continuum of Care ? CFDA Nos. 14.241 and 14.267 Recommendation: We recommend CrescentCare train its employees on the forms to ensure that the date field is completed, and that forms are in tenant files prior to rent payments beginning. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management will develop a process to ensure that all rent reasonableness forms are dated, signed and retained in the file when completed. Management notes that these forms are completed and filed electronically which the date of completion could be verified by the date the form was uploaded to the system. Name of the contact person responsible for corrective action: Andre Duhe at (504) 821-2601. Planned completion date for corrective action plan: March 31, 2020

Federal agency: U.S. Department of Health and Human Services Federal program titles: HIV Emergency Relief Project Grants CFDA Numbers: 93.914 Pass-Through Agencies: City of New Orleans Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Grant recipients are required to track and account for all program income in accordance with 45 CFR 75.302(b)(3). Recipients must report program income on their Federal Financial Report (FFR). HRSA Policy Clarification Notice 15-03 provides guidance on program income, and HRSA issued frequently asked questions on program income as well. It indicates that 340B generated revenue is considered program income for this grant. When an entity is 340B eligible and purchases pharmaceuticals via 340B pricing under multiple awards, the recipient must use a reasonable allocation method for the attribution of costs and program income, and be able to document the methodology used. Condition: Amounts reported for program income on the FFR were determined by a CrescentCare employee based on the number of visits under this grant versus overall visits. Documentation of this calculation and support was not maintained. Subsequently, it was determined that program income waslikely lower based on visit data. Program income was properly used. Context: The amount of program income reported was approximately $386,000; the amount of program income calculated subsequently was approximately $181,000. Cause: Documentation of program income amounts reported could not be located. The employee who prepared the amounts reported left the organization. Effect: Program income could be over or under reported. Recommendation: We recommend CrescentCare maintain documentation of all calculations used for reporting to ensure that program income is properly calculated and reported. Views of responsible officials: Management will develop a process to document the program income calculation. Management notes that the program income calculation is reflective of the revenue and expenses at a moment in time prior to any adjustments. These adjustments may result in a change to the recorded program income for a prior period and require a reconciliation between the initial record and what is now being reported.

U.S. DEPARTMENT OF HEALTH AND HUMAN SERVICES HIV Emergency Relief Project Grants ? CFDA No. 93.914 Recommendation: We recommend CrescentCare maintain documentation of all calculations used for reporting to ensure that program income is properly calculated and reported. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management will develop a process to document the program income calculation. Management notes that the program income calculation is reflective of the revenue and expenses at a moment in time prior to any adjustments. These adjustments may result in a change to the recorded program income for a prior period and require a reconciliation between the initial record and what is now being reported. Name of the contact person responsible for corrective action: Andre Duhe Planned completion date for corrective action plan: March 31, 2020 If there are questions regarding this plan, please call Andre Duhe at (504) 821-2601.

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