Finding 2023-003 Eligibility – Noncompliance and Significant Deficiency in Internal
Control Over Compliance
Identification of the
federal program
ALN 93.210 Tribal Self Governance Program - IHS Compact/Funding
Agreements. Award No. 58G950015-22. Year 2023, 2022 and 2021 (COVID-
19).
Criteria or specific
requirement
In accordance with the IHS funding agreement requirements, as well as
Uniform Guidance compliance requirements, the Association is required
to maintain documentation of eligibility for the patients receiving medical
assistance under the IHS program.
Condition The Organization was unable to provide proper documentation regarding
eligibility of some of the patients for which their accounts were adjusted
to the IHS compact.
Cause The finance department experienced heavy turnover during 2023 that
resulted in several positions being vacant for most of the year. These
staffing shortages resulted in a lack of time for sufficient review.
Effect or potential
effect
Individuals may receive services funded by the IHS program who are
ineligible to receive these benefits.
Questioned Costs Unknown Context We tested 40 patients who were designated as IHS beneficiaries. For 2 of
these patients, documentation proving eligibility was not on file.
Identification as a
repeat finding
None.
Recommendation For all patients receiving services, verification of eligibility should be
documented and kept on file electronically. If eligibility documentation is
not provided, the hospital needs to attempt to collect on the outstanding
balance, rather than charging the IHS Compact. It was noted that the thirdparty
billing service relies on Demographic Patient Information determined
by BBAHC without looking at actual proof of eligibility. We recommend the
Organization require its billing service to confirm documentation on file
prior to IHS adjustments and notify BBAHC if no documentation is retained.
Views of Responsible
Official and Planned
Corrective Action
Management agrees with this finding. Management has reinforced the policy
requiring documentation of beneficiary status and the Patient Access
Manager has developed a registration performance improvement plan.
Finding 2023-003 Eligibility – Noncompliance and Significant Deficiency in Internal
Control Over Compliance
Identification of the
federal program
ALN 93.210 Tribal Self Governance Program - IHS Compact/Funding
Agreements. Award No. 58G950015-22. Year 2023, 2022 and 2021 (COVID-
19).
Criteria or specific
requirement
In accordance with the IHS funding agreement requirements, as well as
Uniform Guidance compliance requirements, the Association is required
to maintain documentation of eligibility for the patients receiving medical
assistance under the IHS program.
Condition The Organization was unable to provide proper documentation regarding
eligibility of some of the patients for which their accounts were adjusted
to the IHS compact.
Cause The finance department experienced heavy turnover during 2023 that
resulted in several positions being vacant for most of the year. These
staffing shortages resulted in a lack of time for sufficient review.
Effect or potential
effect
Individuals may receive services funded by the IHS program who are
ineligible to receive these benefits.
Questioned Costs Unknown Context We tested 40 patients who were designated as IHS beneficiaries. For 2 of
these patients, documentation proving eligibility was not on file.
Identification as a
repeat finding
None.
Recommendation For all patients receiving services, verification of eligibility should be
documented and kept on file electronically. If eligibility documentation is
not provided, the hospital needs to attempt to collect on the outstanding
balance, rather than charging the IHS Compact. It was noted that the thirdparty
billing service relies on Demographic Patient Information determined
by BBAHC without looking at actual proof of eligibility. We recommend the
Organization require its billing service to confirm documentation on file
prior to IHS adjustments and notify BBAHC if no documentation is retained.
Views of Responsible
Official and Planned
Corrective Action
Management agrees with this finding. Management has reinforced the policy
requiring documentation of beneficiary status and the Patient Access
Manager has developed a registration performance improvement plan.
Finding 2023-003 Eligibility – Noncompliance and Significant Deficiency in Internal
Control Over Compliance
Identification of the
federal program
ALN 93.210 Tribal Self Governance Program - IHS Compact/Funding
Agreements. Award No. 58G950015-22. Year 2023, 2022 and 2021 (COVID-
19).
Criteria or specific
requirement
In accordance with the IHS funding agreement requirements, as well as
Uniform Guidance compliance requirements, the Association is required
to maintain documentation of eligibility for the patients receiving medical
assistance under the IHS program.
Condition The Organization was unable to provide proper documentation regarding
eligibility of some of the patients for which their accounts were adjusted
to the IHS compact.
Cause The finance department experienced heavy turnover during 2023 that
resulted in several positions being vacant for most of the year. These
staffing shortages resulted in a lack of time for sufficient review.
Effect or potential
effect
Individuals may receive services funded by the IHS program who are
ineligible to receive these benefits.
Questioned Costs Unknown Context We tested 40 patients who were designated as IHS beneficiaries. For 2 of
these patients, documentation proving eligibility was not on file.
Identification as a
repeat finding
None.
Recommendation For all patients receiving services, verification of eligibility should be
documented and kept on file electronically. If eligibility documentation is
not provided, the hospital needs to attempt to collect on the outstanding
balance, rather than charging the IHS Compact. It was noted that the thirdparty
billing service relies on Demographic Patient Information determined
by BBAHC without looking at actual proof of eligibility. We recommend the
Organization require its billing service to confirm documentation on file
prior to IHS adjustments and notify BBAHC if no documentation is retained.
Views of Responsible
Official and Planned
Corrective Action
Management agrees with this finding. Management has reinforced the policy
requiring documentation of beneficiary status and the Patient Access
Manager has developed a registration performance improvement plan.
Finding 2023-003 Eligibility – Noncompliance and Significant Deficiency in Internal
Control Over Compliance
Identification of the
federal program
ALN 93.210 Tribal Self Governance Program - IHS Compact/Funding
Agreements. Award No. 58G950015-22. Year 2023, 2022 and 2021 (COVID-
19).
Criteria or specific
requirement
In accordance with the IHS funding agreement requirements, as well as
Uniform Guidance compliance requirements, the Association is required
to maintain documentation of eligibility for the patients receiving medical
assistance under the IHS program.
Condition The Organization was unable to provide proper documentation regarding
eligibility of some of the patients for which their accounts were adjusted
to the IHS compact.
Cause The finance department experienced heavy turnover during 2023 that
resulted in several positions being vacant for most of the year. These
staffing shortages resulted in a lack of time for sufficient review.
Effect or potential
effect
Individuals may receive services funded by the IHS program who are
ineligible to receive these benefits.
Questioned Costs Unknown Context We tested 40 patients who were designated as IHS beneficiaries. For 2 of
these patients, documentation proving eligibility was not on file.
Identification as a
repeat finding
None.
Recommendation For all patients receiving services, verification of eligibility should be
documented and kept on file electronically. If eligibility documentation is
not provided, the hospital needs to attempt to collect on the outstanding
balance, rather than charging the IHS Compact. It was noted that the thirdparty
billing service relies on Demographic Patient Information determined
by BBAHC without looking at actual proof of eligibility. We recommend the
Organization require its billing service to confirm documentation on file
prior to IHS adjustments and notify BBAHC if no documentation is retained.
Views of Responsible
Official and Planned
Corrective Action
Management agrees with this finding. Management has reinforced the policy
requiring documentation of beneficiary status and the Patient Access
Manager has developed a registration performance improvement plan.
Finding 2023-003 Eligibility – Noncompliance and Significant Deficiency in Internal
Control Over Compliance
Identification of the
federal program
ALN 93.210 Tribal Self Governance Program - IHS Compact/Funding
Agreements. Award No. 58G950015-22. Year 2023, 2022 and 2021 (COVID-
19).
Criteria or specific
requirement
In accordance with the IHS funding agreement requirements, as well as
Uniform Guidance compliance requirements, the Association is required
to maintain documentation of eligibility for the patients receiving medical
assistance under the IHS program.
Condition The Organization was unable to provide proper documentation regarding
eligibility of some of the patients for which their accounts were adjusted
to the IHS compact.
Cause The finance department experienced heavy turnover during 2023 that
resulted in several positions being vacant for most of the year. These
staffing shortages resulted in a lack of time for sufficient review.
Effect or potential
effect
Individuals may receive services funded by the IHS program who are
ineligible to receive these benefits.
Questioned Costs Unknown Context We tested 40 patients who were designated as IHS beneficiaries. For 2 of
these patients, documentation proving eligibility was not on file.
Identification as a
repeat finding
None.
Recommendation For all patients receiving services, verification of eligibility should be
documented and kept on file electronically. If eligibility documentation is
not provided, the hospital needs to attempt to collect on the outstanding
balance, rather than charging the IHS Compact. It was noted that the thirdparty
billing service relies on Demographic Patient Information determined
by BBAHC without looking at actual proof of eligibility. We recommend the
Organization require its billing service to confirm documentation on file
prior to IHS adjustments and notify BBAHC if no documentation is retained.
Views of Responsible
Official and Planned
Corrective Action
Management agrees with this finding. Management has reinforced the policy
requiring documentation of beneficiary status and the Patient Access
Manager has developed a registration performance improvement plan.
Finding 2023-003 Eligibility – Noncompliance and Significant Deficiency in Internal
Control Over Compliance
Identification of the
federal program
ALN 93.210 Tribal Self Governance Program - IHS Compact/Funding
Agreements. Award No. 58G950015-22. Year 2023, 2022 and 2021 (COVID-
19).
Criteria or specific
requirement
In accordance with the IHS funding agreement requirements, as well as
Uniform Guidance compliance requirements, the Association is required
to maintain documentation of eligibility for the patients receiving medical
assistance under the IHS program.
Condition The Organization was unable to provide proper documentation regarding
eligibility of some of the patients for which their accounts were adjusted
to the IHS compact.
Cause The finance department experienced heavy turnover during 2023 that
resulted in several positions being vacant for most of the year. These
staffing shortages resulted in a lack of time for sufficient review.
Effect or potential
effect
Individuals may receive services funded by the IHS program who are
ineligible to receive these benefits.
Questioned Costs Unknown Context We tested 40 patients who were designated as IHS beneficiaries. For 2 of
these patients, documentation proving eligibility was not on file.
Identification as a
repeat finding
None.
Recommendation For all patients receiving services, verification of eligibility should be
documented and kept on file electronically. If eligibility documentation is
not provided, the hospital needs to attempt to collect on the outstanding
balance, rather than charging the IHS Compact. It was noted that the thirdparty
billing service relies on Demographic Patient Information determined
by BBAHC without looking at actual proof of eligibility. We recommend the
Organization require its billing service to confirm documentation on file
prior to IHS adjustments and notify BBAHC if no documentation is retained.
Views of Responsible
Official and Planned
Corrective Action
Management agrees with this finding. Management has reinforced the policy
requiring documentation of beneficiary status and the Patient Access
Manager has developed a registration performance improvement plan.
Finding 2023-003 Eligibility – Noncompliance and Significant Deficiency in Internal
Control Over Compliance
Identification of the
federal program
ALN 93.210 Tribal Self Governance Program - IHS Compact/Funding
Agreements. Award No. 58G950015-22. Year 2023, 2022 and 2021 (COVID-
19).
Criteria or specific
requirement
In accordance with the IHS funding agreement requirements, as well as
Uniform Guidance compliance requirements, the Association is required
to maintain documentation of eligibility for the patients receiving medical
assistance under the IHS program.
Condition The Organization was unable to provide proper documentation regarding
eligibility of some of the patients for which their accounts were adjusted
to the IHS compact.
Cause The finance department experienced heavy turnover during 2023 that
resulted in several positions being vacant for most of the year. These
staffing shortages resulted in a lack of time for sufficient review.
Effect or potential
effect
Individuals may receive services funded by the IHS program who are
ineligible to receive these benefits.
Questioned Costs Unknown Context We tested 40 patients who were designated as IHS beneficiaries. For 2 of
these patients, documentation proving eligibility was not on file.
Identification as a
repeat finding
None.
Recommendation For all patients receiving services, verification of eligibility should be
documented and kept on file electronically. If eligibility documentation is
not provided, the hospital needs to attempt to collect on the outstanding
balance, rather than charging the IHS Compact. It was noted that the thirdparty
billing service relies on Demographic Patient Information determined
by BBAHC without looking at actual proof of eligibility. We recommend the
Organization require its billing service to confirm documentation on file
prior to IHS adjustments and notify BBAHC if no documentation is retained.
Views of Responsible
Official and Planned
Corrective Action
Management agrees with this finding. Management has reinforced the policy
requiring documentation of beneficiary status and the Patient Access
Manager has developed a registration performance improvement plan.
Finding 2023-003 Eligibility – Noncompliance and Significant Deficiency in Internal
Control Over Compliance
Identification of the
federal program
ALN 93.210 Tribal Self Governance Program - IHS Compact/Funding
Agreements. Award No. 58G950015-22. Year 2023, 2022 and 2021 (COVID-
19).
Criteria or specific
requirement
In accordance with the IHS funding agreement requirements, as well as
Uniform Guidance compliance requirements, the Association is required
to maintain documentation of eligibility for the patients receiving medical
assistance under the IHS program.
Condition The Organization was unable to provide proper documentation regarding
eligibility of some of the patients for which their accounts were adjusted
to the IHS compact.
Cause The finance department experienced heavy turnover during 2023 that
resulted in several positions being vacant for most of the year. These
staffing shortages resulted in a lack of time for sufficient review.
Effect or potential
effect
Individuals may receive services funded by the IHS program who are
ineligible to receive these benefits.
Questioned Costs Unknown Context We tested 40 patients who were designated as IHS beneficiaries. For 2 of
these patients, documentation proving eligibility was not on file.
Identification as a
repeat finding
None.
Recommendation For all patients receiving services, verification of eligibility should be
documented and kept on file electronically. If eligibility documentation is
not provided, the hospital needs to attempt to collect on the outstanding
balance, rather than charging the IHS Compact. It was noted that the thirdparty
billing service relies on Demographic Patient Information determined
by BBAHC without looking at actual proof of eligibility. We recommend the
Organization require its billing service to confirm documentation on file
prior to IHS adjustments and notify BBAHC if no documentation is retained.
Views of Responsible
Official and Planned
Corrective Action
Management agrees with this finding. Management has reinforced the policy
requiring documentation of beneficiary status and the Patient Access
Manager has developed a registration performance improvement plan.