SUMMIT COMMUNITY CARE CLINIC, INC.

Special Tests: Application of Sliding Fee Discount Federal Agency: U.S. Department of Health and Human Services Federal Program: Consolidated Health Centers Grant AL Number: 93.224 & 93.527 Award Period: 1/1/25 - 12/31/25 Type of Finding: Significant Deficiency in Internal Control over Compliance and Compliance 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 that did not have an active sliding fee discount application on file, but the patient received a discounted visit. Effect Potential that a patient would not receive the appropriate sliding fee discount or may receive a discount when they have not applied for one. Questioned Costs None identified. Cause Clerical error in which the sliding fee rate was improperly applied due to lack of an oversight process in place. Recommendation We recommend the Organization to review internal controls in regards to the determination, recording, and monitoring of the sliding fee process to ensure that appropriate sliding fee rates/categories are utilized for each sliding fee encounter and that all documentation supporting the sliding discount provided is retained. Views of Responsible Officials The Organization identified challenges and errors in the prior eligibility workflow after the 2024 audit. Over the course of 2025, the Organization experienced turnover in management and front desk personnel in the dental department. The workflows were modified when the new eligibility manager joined the Organization. Upon hiring a new dental manager and patient access (front desk) manager, workflows and procedures were also modified to ensure the front desk reviews insurance coverage upon check in. The system is set up so the Organization does not need manually adjust all claims, so the claim was auto-posted for the visit identified above. Our corrective action plan is already established, although it was put into place after the date of service of the visit identified above.

2024 – 001 Period of Performance Federal Agency: U.S. Department of Health and Human Services Federal Program: Consolidated Health Centers Grant AL Number: 93.224 & 93.527 Award Period: 1/1/24 - 12/31/24 Type of Finding: Significant deficiency in Internal Control over Compliance and Compliance Criteria or Specific Requirement According to § 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. According to 2 CFR 200.1 Period of Performance is defined as the total estimated time interval between the start of an initial Federal award and the planned end date, which may include one or more funded portions, or budget periods. Condition and Context The Organization began allocating direct salaries and benefits prior to the awards period of performance start date. The Organization allocated expenditures based on the payroll paid date, rather than the date the payroll was incurred. Total direct salaries and benefits allocated to the grant prior to the period of performance start date was $21,049. Effect Potential that costs will be charged to the grant outside of the period of performance. Questioned Costs $21,049 Cause The Organization allocated payroll expenditures based on the paid date, rather than the incurred date. Recommendation We recommend the Organization update their method of allocating expenditures to federal awards based on the incurred date, rather than paid date.Views of Responsible Officials The Organization corrected the period of performance finding prior to the 2024 audit being completed and feel this was an isolated incident. The issue was caused by staff turnover in 2024, and new staff have been properly trained to review all grants to ensure compliance with all grant regulations. This grant can be used for staffing costs and upon identification of this issue we have corrected the allocations to the prior grant periods. Going forward, the Organization has implemented controls to ensure that all staff are being trained to ensure they are following grant guidelines.

2024 – 002 Suspension and Debarment Federal Agency: U.S. Department of Treasury Federal Program: Coronavirus State and Local Fiscal Recovery Funds AL Number: 21.027 Award Period: 9/21/23 - 6/30/25 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 & debarment, we noted one instance in which the Organization did not perform the suspension and debarment check prior to entering into a transaction with a vendor. Effect Noncompliance results in possible federal funds provided to ineligible vendors. Questioned Costs None Cause The debarment check for one vendor was not completed until after the invoice was paid. Recommendation We recommend that the Organization implement a process to ensure suspension and debarment checks are performed and documentation is retained to show that the checks are occurring prior to entering into transactions with vendors.Views of Responsible Officials The Organization has internal staffing challenges within the accounting department in 2024 resulting in turnover. The Organization has a process in place to check vendors against the OIG exclusion list when the vendor is added to the accounts payable system and prior to paying the vendor. This vendor applied the wire payment one day prior to the Organization running the check against the exclusion list. The Organization was under the impression that the vendor would not execute the wire on that date. The Organization did perform a suspension and debarment check subsequent to the payment being made, and no findings were found for the vendor. We believe the payment was expedited by the vendor due to their implementation timeline and feel this is an isolated one-time event.

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 that received the incorrect sliding fee discount.

Effect Potential that a patient would not receive the appropriate sliding fee discount.

Questioned Costs None identified.

Cause Clerical error in which the incorrect discount was applied due to lack of an oversight process in place.

Recommendation We recommend the Organization to review internal controls in regards to the determination, recording, and monitoring of the sliding fee process to ensure that appropriate sliding fee rates/categories are utilized for each sliding fee encounter.

Views of Responsible Officials The Organization acknowledges the error identified in the sliding fee discount. To address this issue and prevent future occurrences, the following corrective actions will be implemented:

1. Internal Audit Procedure • An internal audit procedure will be established to review 10% of the applications processed by each eligibility worker. This review will include verification of application accuracy, calculation correctness, and appropriate selection of sliding fee scales.

2. Identification of Errors • During the internal audit, if any errors are found, immediate action will be taken to rectify the identified mistakes.

3. Retraining and Testing • In cases where errors are detected, affected staff will undergo retraining. This retraining will cover all relevant processes and guidelines to ensure a thorough understanding.

• Post-retraining, the staff will be subjected to a period of testing to confirm their competence in handling the sliding fee discount applications accurately.

These steps will help ensure the integrity and accuracy of the Sliding Fee Discount program moving forward.