MARILLAC COMMUNITY HEALTH CENTERS

Criteria: Per HRSA Compliance Manual, Chapter 9: Sliding Fee Discount Program, Federally Qualified Health Centers (FQHCs) and similar entities are required to maintain and apply a Board-approved sliding fee scale based on income and family size. The scale must be applied uniformly to all eligible patients to ensure compliance with 42 U.S.C. § 254b and HRSA program requirements. Condition: During our testing of the sliding fee discounts under the Special Tests and Provisions compliance requirement, the audit team noted that the entity did not consistently apply its Board-approved sliding fee scale for medical and dental services. Specifically, in a nonstatistical sample of forty patient encounters tested, four instances were identified where the sliding fee discount applied was inconsistent with the entity’s approved sliding fee scale or was not supported by the documented patient inco…

Corrective action: The organization has implemented additional levels of review and pre­screening of slide patient data to ensure accuracy and that the data is complete. Routine reviews done by front desk supervisors will be further documented in order to provide additional training to staff as needed. Results of monthly audits performed by service line leaders will be reported to senior leadership. An internal audit will be done by the compliance team and presented to leadership on a quarterly basis. All appropriate admitting staff will go through training to reinforce our slide process and review procedures for all FQHC services.

Federal Agency: US Department of Health and Human Services Federal Program: Congressionally Delegated Spending for Construction Projects AL Number: 93.493 Award Period: 1/1/25 – 12/31/25 Type of Finding: Significant deficiency in Internal Control Over Compliance and Compliance Criteria or Specific Requirement 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of procurement and suspension and debarment. The Organization should have internal controls designed to ensure compliance with these provisions. Condition and Context During our testing over Suspension and Debarment, noted one instance in which the Organization was unable to locate documentation that a suspension and debarment check was performed prior to entering into a transaction with a vendor. Effect Noncompliance results in possib…

Corrective action: Federal Program: Congressionally Delegated Spending for Construction Projects Assistance Listing No. 93.493 Recommendation: Our auditors recommend the Organization implement a process to ensure that procurement and suspension and debarment documentation is retained. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Organization acknowledges that, in one instance, documentation evidencing that a suspension and debarment check was performed prior to engaging a vendor could not be located. While this appears to be an isolated occurrence, we recognize the importance of maintaining complete and auditable docum…

Federal Agency: US Department of Health and Human Services Federal Program: Congressionally Delegated Spending for Construction Projects Pass-Through Agency: N/A AL Number: 93.493 Award Period: 1/1/25 – 12/31/25 Type of Finding: Significant deficiency in Internal Control Over Compliance and Compliance Criteria or Specific Requirement 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of procurement and suspension and debarment. The Organization should have internal controls designed to ensure compliance with these provisions. Condition and Context During our testing over Procurement noted two instances in which the Organization was unable to locate documentation that agreements with vendors related to the infrastructure project included the Buy America domestic preference provisions in each…

Corrective action: Federal Program: Congressionally Delegated Spending for Construction Projects Assistance Listing No. 93.493 Recommendation: Our auditors recommend the Organization implement a process to ensure that procurement agreements with vendors related to infrastructure projects include the Buy America domestic preference provisions in each agreement, or a process to obtain a BABA (Build America, Buy America) waiver. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Organization was unable to locate documentation demonstrating that procurement agreements included the required Buy America (BABA) provisions or eviden…

Criteria or Specific Requirement Per Title 42 Chapter 1 Subchapter D Section 51c303(f), “Health centers must have a schedule of fees or payments for the provision of their health services consistent with locally prevailing rates or charges designed to cover their reasonable costs of operation. They are also required to have a corresponding schedule of discounts applied and adjusted on the basis of the patient’s ability to pay.” Condition and Context During our testing of forty sliding fee discounts for health center patients qualifying for reduced charge visits, we identified one visit where a sliding fee application could not be found to support the slide provided. Effect Potential that a patient would not receive the appropriate sliding fee discount. Questioned Costs None identified. Cause Clerical error in which the sliding fee application was not saved in the patients file. Rec…

Corrective action: Federal Program: Consolidated Health Centers Grant Assistance Listing No. 93.224 & 93.527 Recommendation: Our auditors recommended the Organization to review internal controls in regards to retaining the completed sliding fee applications in the patients record to support the sliding fee discount provided to the patient. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management agrees that this was a clerical error and an isolated incident. To improve the process and minimize errors, eligibility applications will now be processed at the Grand Junction, Colorado office by a different eligibility staff. Thi…

Criteria or Specific Requirement 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of procurement and suspension and debarment. The Organization should have internal controls designed to ensure compliance with these provisions. Condition and Context During our testing over suspension and debarment, we noted one instance in which the Organization was unable to locate documentation that a suspension and debarment check was performed prior to entering into a transaction with a vendor. Effect Noncompliance results in possible federal funds provided to ineligible vendors. Questioned Costs None identified. Cause The Organization does not have internal controls in place to ensure compliance with federal regulations or the terms and conditions of the federal award. Recommendation We recommen…

Corrective action: Federal Program: Covid-19: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing No. 21.027 Recommendation: Our auditors recommended the Organization implement a process to ensure that procurement and suspension and debarment documentation is retained. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Organization has a program called Compliatric that the Organization can load all of its vendors into and it will check on a monthly basis the registries for Debarment and Exclusions from Federal Programs with a log to track this screening. The Organization has changed the accounts payable proc…

Criteria or Specific Requirement Per Title 42 Chapter 1 Subchapter D Section 51c303(f), “Health centers must have a schedule of fees or payments for the provision of their health services consistent with locally prevailing rates or charges designed to cover their reasonable costs of operation. They are also required to have a corresponding schedule of discounts applied and adjusted on the basis of the patient’s ability to pay.” Condition and Context During our testing of forty sliding fee discounts for health center patients qualifying for reduced charge visits, we identified two visits where a sliding fee application could not be found to support the slide provided. We noted that both visits selected by our random sample were related to the same patient. Effect Potential that a patient would not receive the appropriate sliding fee discount. Questioned Costs None identified. Cause Cl…

Corrective action: Federal Program: Consolidated Health Centers Grant Assistance Listing No. 93.224 & 93.527 Recommendation: Our auditors recommended the Organization to review internal controls in regards to retaining the completed sliding fee applications in the patients record to support the sliding fee discount provided to the patient. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Organization agrees that this is a clerical error and an isolated incident. Currently, eligibility staff receives completed applications, scans them into the electronic health record, and discards the hard copy. To minimize error, the p…