Audit 394296

Finding #: 2024-002 Special Tests and Provisions – Noncompliance (not material to compliance requirement) Identification of Federal Program and Award Program title: Health Centers Cluster - 93.224 Community Health Centers, 93.527 Affordable Care Act (ACA) Grants for New and Expanded Services Under the Health Center Program CFDA #: 93.224/93.527 Award #: 4 H8FCS40520-01-05 Program Year: 2024 Criteria Pursuant to 42 CFR section 56.303(g)(2), health centers must make every reasonable effort, including the establishment of systems for eligibility determination, billing, and collection, to secure from patients, payments for services in accordance with the schedule of fees and discounts. Condition During our testing of special tests and provisions, we noted instances of noncompliance relating to the health center’s application of sliding fee discounts to patient charges; 4 out of 23 patient records sampled showed instances where patient charges were not appropriately adjusted to be consistent with the sliding fee discount schedule and/or the application was incorrectly rated. Cause Personnel were not following CAMcare’s Financial Sliding Fee Scale Policies and Procedures, which comply with 42 CFR section 56.303(g)(2). Additionally, a revised sliding fee scale was implemented as of 7/1/2024 with updated scale ratings. As a result, patients were not charged in accordance to their sliding fee based on the HRSA sliding fee schedule. Effect Possibility of underbilling or overbilling patients is based on incorrectly applying rates according to the sliding fee scale, which is based on income. Questioned Costs None Perspective Information We tested a statistically valid sample of 23 patient encounters out of a total population of 4,803 uncompensated care program encounters and determined that the audit finding represented a systemic problem. Repeat Finding This is a repeat Finding # 2023-002. Recommendation We recommend that management review financial sliding fee scale policies and procedures in place and closely monitor the patient billing process to ensure CAMcare is in compliance with the compliance requirements of 42 CFR section 56.303(g)(2). Prior to registering patient visits, front desk personnel (i.e., Intake) should review patient application information to ensure the information agrees to the registration system. Any information that does not reconcile should be reviewed and corrected by the financial screening team promptly, and prior to applying the sliding fee discount to patient billing records. Additionally, any time CAMcare revises/updates their sliding fee discount schedule, all necessary personnel should be notified of the revisions, and the financial screening team should review and update patient applications accordingly. Such revisions/updates to the scale should be reflected in the billing system promptly upon implementation of the revised scale. Views of Responsible Officials Management agrees with the underlying control concern and has taken steps to strengthen compliance with CAMcare’s financial screening and sliding fee policies, including but not limited to reinforcing staff training, improving communication and implementation procedures when fee scales are updated, and enhancing front desk and financial screening review to ensure that the patient’s application rating and Epic FPL table align prior to discounts being applied in billing. Management will continue monitoring compliance through periodic spot checks and supervisory review to reduce the likelihood of recurrence.