2022-001 Sliding Fee Discounts
Criteria: Syracuse Community Health Center, Inc. (the Center) is required to have a sliding fee scale policy and to perform calculations in accordance with the established policy. The Center should be implementing and monitoring procedures to properly determine, calculate and review sliding fee discounts given to patients in accordance with the Center's sliding fee scale.
Condition: During our audit, we attempted to test a haphazardly sample of 40 sliding fee scale calculations. Two patients received an inappropriate slide based on the application and supporting documentation. Two applications were not completed in accordance with the terms of the Center’s policy.
Context: We recalculated the sliding fee using the supporting income documentation maintained by the Center and the Center’s policy. The sample was not a statistically valid sample.
Effect: The Center is not properly maintaining sliding fee scale documentation for patients or applying the slide to patient charges properly.
Cause: The condition can be attributed to human error and the lack of internal controls to review and ensure that the proper documentation is being maintained and that proper sliding fee discounts are being applied.
Recommendation: The sliding fee scale option is available as a result of grant funding. The Center should review and strengthen the current procedures in place for determining a patient’s financial responsibility for their visit using the sliding fee scale. This should include requiring a knowledgeable representative of the Center’s signature approval on the documentation received and the fee calculated and provided to the applicant. All applications should contain support for the individual’s income level or documentation of no income, and the determination of the resulting fee.
Views of management and planned corrective action: This finding was repeated in 2022. Since this was a repeat finding, an internal audit was performed on all 2023 approved sliding fee applications to ensure compliance with our policy. Any corrective actions to the 2023 application were address and the facility’s sliding fee scale was modified to reflect proper authorization and proper segregation of duties going forward. Going forward, all sliding fee scale applications are now reviewed and authorized by the Manager of Revenue Cycle. Future auditing procedures have been put in place to review applications and adjusted, if needed, in a timely manner between now and the end of the year.
2022-001 Sliding Fee Discounts
Criteria: Syracuse Community Health Center, Inc. (the Center) is required to have a sliding fee scale policy and to perform calculations in accordance with the established policy. The Center should be implementing and monitoring procedures to properly determine, calculate and review sliding fee discounts given to patients in accordance with the Center's sliding fee scale.
Condition: During our audit, we attempted to test a haphazardly sample of 40 sliding fee scale calculations. Two patients received an inappropriate slide based on the application and supporting documentation. Two applications were not completed in accordance with the terms of the Center’s policy.
Context: We recalculated the sliding fee using the supporting income documentation maintained by the Center and the Center’s policy. The sample was not a statistically valid sample.
Effect: The Center is not properly maintaining sliding fee scale documentation for patients or applying the slide to patient charges properly.
Cause: The condition can be attributed to human error and the lack of internal controls to review and ensure that the proper documentation is being maintained and that proper sliding fee discounts are being applied.
Recommendation: The sliding fee scale option is available as a result of grant funding. The Center should review and strengthen the current procedures in place for determining a patient’s financial responsibility for their visit using the sliding fee scale. This should include requiring a knowledgeable representative of the Center’s signature approval on the documentation received and the fee calculated and provided to the applicant. All applications should contain support for the individual’s income level or documentation of no income, and the determination of the resulting fee.
Views of management and planned corrective action: This finding was repeated in 2022. Since this was a repeat finding, an internal audit was performed on all 2023 approved sliding fee applications to ensure compliance with our policy. Any corrective actions to the 2023 application were address and the facility’s sliding fee scale was modified to reflect proper authorization and proper segregation of duties going forward. Going forward, all sliding fee scale applications are now reviewed and authorized by the Manager of Revenue Cycle. Future auditing procedures have been put in place to review applications and adjusted, if needed, in a timely manner between now and the end of the year.
2022-001 Sliding Fee Discounts
Criteria: Syracuse Community Health Center, Inc. (the Center) is required to have a sliding fee scale policy and to perform calculations in accordance with the established policy. The Center should be implementing and monitoring procedures to properly determine, calculate and review sliding fee discounts given to patients in accordance with the Center's sliding fee scale.
Condition: During our audit, we attempted to test a haphazardly sample of 40 sliding fee scale calculations. Two patients received an inappropriate slide based on the application and supporting documentation. Two applications were not completed in accordance with the terms of the Center’s policy.
Context: We recalculated the sliding fee using the supporting income documentation maintained by the Center and the Center’s policy. The sample was not a statistically valid sample.
Effect: The Center is not properly maintaining sliding fee scale documentation for patients or applying the slide to patient charges properly.
Cause: The condition can be attributed to human error and the lack of internal controls to review and ensure that the proper documentation is being maintained and that proper sliding fee discounts are being applied.
Recommendation: The sliding fee scale option is available as a result of grant funding. The Center should review and strengthen the current procedures in place for determining a patient’s financial responsibility for their visit using the sliding fee scale. This should include requiring a knowledgeable representative of the Center’s signature approval on the documentation received and the fee calculated and provided to the applicant. All applications should contain support for the individual’s income level or documentation of no income, and the determination of the resulting fee.
Views of management and planned corrective action: This finding was repeated in 2022. Since this was a repeat finding, an internal audit was performed on all 2023 approved sliding fee applications to ensure compliance with our policy. Any corrective actions to the 2023 application were address and the facility’s sliding fee scale was modified to reflect proper authorization and proper segregation of duties going forward. Going forward, all sliding fee scale applications are now reviewed and authorized by the Manager of Revenue Cycle. Future auditing procedures have been put in place to review applications and adjusted, if needed, in a timely manner between now and the end of the year.
2022-002 Reporting
Criteria: The Center is required to submit Provider Relief Fund reports that account for and certify to the eligibility of expenses and lost revenues with HRSA.
Condition: During our audit, we reviewed the Period 4 Provider Relief Fund reporting, noting that it was submitted timely; however, it was not reviewed by an appropriate level of management prior to submission. As a result, we noted that the reporting was not completed accurately based on the Center’s operations. Through review of this reporting, it was noted that the Center reported unreimbursed “Healthcare Related Expenditures” of $993,538 and $0 for the years ended December 31, 2021 and 2022, respectively, which was used in the Period 4 reporting period. It was determined that this information reported was not accurate and instead the Center should have reported unreimbursed “Healthcare Related Expenditures” of $0 and $321,109 for the years ended December 31, 2021 and 2022 to be used in the Period 4 reporting period. In addition to the revised expenses, the Center had unused lost revenues of $4,288,165 of which $672,429 should have been used in the Period 4 reporting period.
Context: During 2022, the Center experienced nearly 100% turnover in its finance department. Part of this turnover included the Director of Grants Management who started in November 2022 and departed in May 2023. The Director of Grants Management completed the Period 4 report without review by an appropriate level of management with historical knowledge of the usage of these funds to allow for accurate reporting. During 2021 and 2022, the Center operated as a COVID-19 test site for the Central New York community and has experienced a significant decrease in visit volume as a result of the COVID-19 pandemic.
Cause: The incorrect reporting can be attributed to turnover in staffing and lack of review of reporting by an individual with the appropriate knowledge prior to submission.
Effect: The Center is at risk of having Period 4 Provider Relief Funds returned to HRSA as the Center was not in compliance with the Provider Relief Fund compliance supplement. Recommendation: We recommend that the Center review and strengthen current procedures regarding review of reporting by an appropriate level of management prior to submission. Additionally, we recommend that the Center work with HRSA to take corrective action to rectify this reporting matter.
Views of management and planned corrective action: The accounting department had a significant turnover during 2022 which cause reporting errors go unreviewed. Since 2023, the appropriate accounting team has been assembled and proper policies, procedures, authorization, segregation of duties and reviews have been put in place so that going forward this will not be an issue. All reporting is now being reviewed prior to submission so that reporting requirements including proper period and proper information is reported correctly. We have proactively reached out to the PRF Reporting Help Desk to correct the reporting and communicated the noted reporting corrections needed.
2022-001 Sliding Fee Discounts
Criteria: Syracuse Community Health Center, Inc. (the Center) is required to have a sliding fee scale policy and to perform calculations in accordance with the established policy. The Center should be implementing and monitoring procedures to properly determine, calculate and review sliding fee discounts given to patients in accordance with the Center's sliding fee scale.
Condition: During our audit, we attempted to test a haphazardly sample of 40 sliding fee scale calculations. Two patients received an inappropriate slide based on the application and supporting documentation. Two applications were not completed in accordance with the terms of the Center’s policy.
Context: We recalculated the sliding fee using the supporting income documentation maintained by the Center and the Center’s policy. The sample was not a statistically valid sample.
Effect: The Center is not properly maintaining sliding fee scale documentation for patients or applying the slide to patient charges properly.
Cause: The condition can be attributed to human error and the lack of internal controls to review and ensure that the proper documentation is being maintained and that proper sliding fee discounts are being applied.
Recommendation: The sliding fee scale option is available as a result of grant funding. The Center should review and strengthen the current procedures in place for determining a patient’s financial responsibility for their visit using the sliding fee scale. This should include requiring a knowledgeable representative of the Center’s signature approval on the documentation received and the fee calculated and provided to the applicant. All applications should contain support for the individual’s income level or documentation of no income, and the determination of the resulting fee.
Views of management and planned corrective action: This finding was repeated in 2022. Since this was a repeat finding, an internal audit was performed on all 2023 approved sliding fee applications to ensure compliance with our policy. Any corrective actions to the 2023 application were address and the facility’s sliding fee scale was modified to reflect proper authorization and proper segregation of duties going forward. Going forward, all sliding fee scale applications are now reviewed and authorized by the Manager of Revenue Cycle. Future auditing procedures have been put in place to review applications and adjusted, if needed, in a timely manner between now and the end of the year.
2022-001 Sliding Fee Discounts
Criteria: Syracuse Community Health Center, Inc. (the Center) is required to have a sliding fee scale policy and to perform calculations in accordance with the established policy. The Center should be implementing and monitoring procedures to properly determine, calculate and review sliding fee discounts given to patients in accordance with the Center's sliding fee scale.
Condition: During our audit, we attempted to test a haphazardly sample of 40 sliding fee scale calculations. Two patients received an inappropriate slide based on the application and supporting documentation. Two applications were not completed in accordance with the terms of the Center’s policy.
Context: We recalculated the sliding fee using the supporting income documentation maintained by the Center and the Center’s policy. The sample was not a statistically valid sample.
Effect: The Center is not properly maintaining sliding fee scale documentation for patients or applying the slide to patient charges properly.
Cause: The condition can be attributed to human error and the lack of internal controls to review and ensure that the proper documentation is being maintained and that proper sliding fee discounts are being applied.
Recommendation: The sliding fee scale option is available as a result of grant funding. The Center should review and strengthen the current procedures in place for determining a patient’s financial responsibility for their visit using the sliding fee scale. This should include requiring a knowledgeable representative of the Center’s signature approval on the documentation received and the fee calculated and provided to the applicant. All applications should contain support for the individual’s income level or documentation of no income, and the determination of the resulting fee.
Views of management and planned corrective action: This finding was repeated in 2022. Since this was a repeat finding, an internal audit was performed on all 2023 approved sliding fee applications to ensure compliance with our policy. Any corrective actions to the 2023 application were address and the facility’s sliding fee scale was modified to reflect proper authorization and proper segregation of duties going forward. Going forward, all sliding fee scale applications are now reviewed and authorized by the Manager of Revenue Cycle. Future auditing procedures have been put in place to review applications and adjusted, if needed, in a timely manner between now and the end of the year.
2022-001 Sliding Fee Discounts
Criteria: Syracuse Community Health Center, Inc. (the Center) is required to have a sliding fee scale policy and to perform calculations in accordance with the established policy. The Center should be implementing and monitoring procedures to properly determine, calculate and review sliding fee discounts given to patients in accordance with the Center's sliding fee scale.
Condition: During our audit, we attempted to test a haphazardly sample of 40 sliding fee scale calculations. Two patients received an inappropriate slide based on the application and supporting documentation. Two applications were not completed in accordance with the terms of the Center’s policy.
Context: We recalculated the sliding fee using the supporting income documentation maintained by the Center and the Center’s policy. The sample was not a statistically valid sample.
Effect: The Center is not properly maintaining sliding fee scale documentation for patients or applying the slide to patient charges properly.
Cause: The condition can be attributed to human error and the lack of internal controls to review and ensure that the proper documentation is being maintained and that proper sliding fee discounts are being applied.
Recommendation: The sliding fee scale option is available as a result of grant funding. The Center should review and strengthen the current procedures in place for determining a patient’s financial responsibility for their visit using the sliding fee scale. This should include requiring a knowledgeable representative of the Center’s signature approval on the documentation received and the fee calculated and provided to the applicant. All applications should contain support for the individual’s income level or documentation of no income, and the determination of the resulting fee.
Views of management and planned corrective action: This finding was repeated in 2022. Since this was a repeat finding, an internal audit was performed on all 2023 approved sliding fee applications to ensure compliance with our policy. Any corrective actions to the 2023 application were address and the facility’s sliding fee scale was modified to reflect proper authorization and proper segregation of duties going forward. Going forward, all sliding fee scale applications are now reviewed and authorized by the Manager of Revenue Cycle. Future auditing procedures have been put in place to review applications and adjusted, if needed, in a timely manner between now and the end of the year.
2022-002 Reporting
Criteria: The Center is required to submit Provider Relief Fund reports that account for and certify to the eligibility of expenses and lost revenues with HRSA.
Condition: During our audit, we reviewed the Period 4 Provider Relief Fund reporting, noting that it was submitted timely; however, it was not reviewed by an appropriate level of management prior to submission. As a result, we noted that the reporting was not completed accurately based on the Center’s operations. Through review of this reporting, it was noted that the Center reported unreimbursed “Healthcare Related Expenditures” of $993,538 and $0 for the years ended December 31, 2021 and 2022, respectively, which was used in the Period 4 reporting period. It was determined that this information reported was not accurate and instead the Center should have reported unreimbursed “Healthcare Related Expenditures” of $0 and $321,109 for the years ended December 31, 2021 and 2022 to be used in the Period 4 reporting period. In addition to the revised expenses, the Center had unused lost revenues of $4,288,165 of which $672,429 should have been used in the Period 4 reporting period.
Context: During 2022, the Center experienced nearly 100% turnover in its finance department. Part of this turnover included the Director of Grants Management who started in November 2022 and departed in May 2023. The Director of Grants Management completed the Period 4 report without review by an appropriate level of management with historical knowledge of the usage of these funds to allow for accurate reporting. During 2021 and 2022, the Center operated as a COVID-19 test site for the Central New York community and has experienced a significant decrease in visit volume as a result of the COVID-19 pandemic.
Cause: The incorrect reporting can be attributed to turnover in staffing and lack of review of reporting by an individual with the appropriate knowledge prior to submission.
Effect: The Center is at risk of having Period 4 Provider Relief Funds returned to HRSA as the Center was not in compliance with the Provider Relief Fund compliance supplement. Recommendation: We recommend that the Center review and strengthen current procedures regarding review of reporting by an appropriate level of management prior to submission. Additionally, we recommend that the Center work with HRSA to take corrective action to rectify this reporting matter.
Views of management and planned corrective action: The accounting department had a significant turnover during 2022 which cause reporting errors go unreviewed. Since 2023, the appropriate accounting team has been assembled and proper policies, procedures, authorization, segregation of duties and reviews have been put in place so that going forward this will not be an issue. All reporting is now being reviewed prior to submission so that reporting requirements including proper period and proper information is reported correctly. We have proactively reached out to the PRF Reporting Help Desk to correct the reporting and communicated the noted reporting corrections needed.