Community Health Centers of Central Wyoming, Inc.Non-Profit

Finding 2025-001 Application of Sliding Fee Discount Program Information: Federal AgencyU.S. Department of Health and Human Services Federal Assistance Listing Number 93.224 and 93.527 Health Center Program Cluster Award NumberH80CS000564 Criteria[X] Compliance Finding [X] Significant Deficiency [ ] Material Weakness OMB 2 CFR 200, 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 patient’s ability to pay.” Condition In our testing of 25 sliding fee discounts for health center patients qualifying for reduced charge visits, we identified 1 instance where a patient was eligible to receive a sliding fee discount but no discount was applied. We also identified 1 instance where the incorrect sliding fee was applied to the patient. We also noted 1 application did not indicate review and approval of the sliding fee application by an appropriate staff at the Organization. Cause The Center did not have a review process in place to verify eligible patients completed the required application to receive a sliding fee discount and that each application contained the required information. Additionally, the Center did not verify the correct sliding fee discount was based on the Center’s sliding fee scale. Context The finding appears to be a systemic problem. Effect Incomplete applications could indicate that patients who received a sliding fee discount may not have been eligible. Additionally, the sliding fee discount could be applied incorrectly and not in accordance with the Center’s policy. Recommendation We recommend continued effort in training personnel on applying the appropriate sliding fee discount based on the Center’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 The CFO, Revenue Cycle Manager, Revenue Cycle Coordinator, and billing staff will begin to implement a peer review process of the sliding fee scale applications monthly. Management will develop a peer review form, train the staff on the form and process to review each application to ensure compliance with the approved policy.

2022-001 Provider Relief Fund Reporting of Lost Revenue Federal Agency Department of Health and Human Services Assistance Listing Number 93.498 ? Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution Criteria: [ ] Significant Deficiency [X] Material Weakness [X] Compliance Finding Under the terms and conditions of the award, the recipient certifies it will report actual net patient revenues for the periods reported in its reporting of actual net patient revenues for its calculation of lost revenues due to coronavirus. Condition: The Organization?s fiscal year 2021 allowance for contractual adjustments and bad debt was understated, causing net patient service revenue to be overstated, resulting in audit adjustments to the Organization?s fiscal year 2021 financial statements. As a result, net patient service revenues were not accurately reported for the 2nd, 3rd, and 4th quarters of calendar year 2020 and the 1st quarter of calendar year 2021 on its Period 1 Provider Relief Fund report. Context: This finding appears to be an isolated problem. Cause: The Organization prepared its lost revenue calculations using system reports which were not reflective of necessary adjustments to net patient service revenue, which were later posted to its fiscal year 2021 financial statements. Effect: The actual net patient service revenues for the 2nd, 3rd, and 4th quarters of calendar year 2020 and the 1st quarter of calendar year 2021 did not reflect the correct amounts to be used in its lost revenue calculations. If the net patient service revenues were reported correctly, the Organization would still have sufficient lost revenues to cover all of the Provider Relief Fund amounts received. Therefore, there is no effect on the Organization?s retention of the Provider Relief Funds. Recommendation: We recommend the Organization correct its lost revenue calculation in subsequent period reporting for the Provider Relief Fund. Views of responsible officials and planned corrective actions: This finding is the same finding from the previous year?s audit regarding our contractual adjustments and bad debt being understated. Our response then ? Community Health Centers of Central Wyoming will record patient refunds payable at year end as a liability rather than as a credit to accounts receivable and will also record prepaid dental services as deferred revenue rather than a credit to accounts receivable. In calculating a bad debt allowance, Community Health Centers of Central Wyoming will not extend the period that the bad debt allowance is based on beyond six months ? is still valid for this issue. Our financials were updated after reporting for Provider Relief Funds which resulted in understatement of the contractual allowance. We have corrected the issue of calculating the allowance as of March 31, 2022. We will correct the lost revenue on the next PRF reporting cycle.

Program Information: Federal Agency: U.S. Department of Health and Human Services CFDA: 93.224 and 93.527 Health Centers Cluster Criteria: Compliance Finding: OMB 2 CFR 200, Subpart N 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 patient?s ability to pay.? Condition: In our testing of 25 sliding fee discounts for health center patients qualifying for reduced charge visits, we identified one instance of an incorrect sliding fee application. We also identified one incident where the correct sliding fee was applied but the Organization?s support to calculate the appropriate slide did not match. Context: The finding appears to be an isolated problem. Effect: Financial reports may be inaccurate and could affect management and Board decision making. Cause: The Organization lacked proper training and oversight of internal processes used to determine the appropriate sliding fee to apply to patients. Recommendation: We recommend personnel be properly trained on applying appropriate sliding fee discounts based on the Organization?s approved policy and compliance with grant requirements. We recommend an appropriate level of review be conducted on patient accounts to ensure proper application of sliding fee discounts. Views of responsible officials and planned corrective action.:1) The health center has operating procedures for assessing/re-assessing all patients for income and family size consistent with board-approved sliding fee discount program policies. 2) The health center has records of assessing and re-assessing patient income and family size except in situations where a patient has declined or refused to provide such information. In this case, the patient would not be eligible for accessing the slide. 3) CHCCW personnel have gone back to the very sample and did review what transpired. The slide calculation used was based on net income and not gross income. This does appear to be the essence of the error in the slide finding, an error due to what could be many reasons on any given day. The employee involved left the organization during fiscal year 2018. Our internal record does indicate that after a review of this slide by other personnel, the error was caught and the sliding fee scale was manually expired in the system due to the incorrect calculation. The internal record also indicates this error only impacted one (1) claim for the patient. 4) During fiscal year 2018, a registration audit process was implemented to include a component for reviewing sliding fee scale discounts and the associated documentation and calculations. Staff have been sufficiently trained and the Patient Support Manager went so far as to set up a process where only seasoned and tenured staff are eligible to process sliding fee scale discounts and calculations; this is a core group of four staff members.

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