ReGenesis Health Care Corrective Action Plan
Audit period: July 1, 2023 - June 30, 2024
Audit Finding: Incorrect Application of Sliding Fee Scale and Lack of Proper Documentation
________________________________________
Summary of Audit Finding – Federal Award Program Audit
Department of Health an...
ReGenesis Health Care Corrective Action Plan
Audit period: July 1, 2023 - June 30, 2024
Audit Finding: Incorrect Application of Sliding Fee Scale and Lack of Proper Documentation
________________________________________
Summary of Audit Finding – Federal Award Program Audit
Department of Health and Human Services
2024-001 Health Centers Cluster – Assistance Listing No. 93.224
In a sample of 25 patient accounts, the audit revealed:
• Four instances where the incorrect sliding fee scale was applied and lack of proper documentation maintained for sliding fee applications.
________________________________________
Corrective Actions:
Staff Training
Action:
• Conduct mandatory training for General Practice Managers (GPMs) and Patient Service Representatives (PSRs), as well as for all newly hired front desk staff at orientation and annually thereafter.
Content:
• Process for sliding fee discount program eligibility determination.
• Proper application of the sliding fee scale.
• Documentation standards and quality improvement/assurance measures.
Timeline: Begin training within 30 days from 1/21/25 and establish ongoing annual sessions.
Responsible Party: Senior GPM, VP Strategy & Development
Action Plan for Slide Application Process:
PSR Responsibilities:
• Continue scanning all completed slide applications into the system on the same day they are completed.
• Ensure all relevant information is entered into the patient’s chart.
• Assign scanned slide applications to respective GPMs for review in eCW.
GPM Responsibilities:
• Review slide applications in D jellybean daily for accuracy. The review should ensure that:
o The document has been scanned into the chart.
o Calculations are correct.
o The correct proof of income and supporting documentation are included.
• Discuss any slides requiring correction with the PSR and provide continued education as needed.
• Address excessive errors through performance improvement plans and disciplinary actions if necessary.
• GPM to ensure sliding fee schedule is correct and all documentation is present before marking the documents as approved in eCW.
Auditing:
• GPMs will run daily reports in eCW to audit the front desk’s slide application process.
• Physicians Services Billing Manager or designee to review slide application information to ensure correct sliding scale has been applied.
• Director of Quality Improvement will also audit process to ensure GPMs are completing this expectation.
Standardized Procedures
Action:
• Review and update the Sliding Fee Discount Program Policy and Procedures annually and as needed
• Implement a checklist for staff to ensure proper documentation.
• The Physician Services Billing Manager will train billing staff on applying sliding fee discount program adjustments and will conduct internal audits to ensure the accuracy of payer status.
Timeline: Review current policies and procedures by 2/7/25.
Responsible Party: Senior GPM, Chief Financial Officer and Chief Administrative Officer
Quality Control Measures
Action:
• Establish a quality control process to regularly review sliding fee documentation and application accuracy.
Frequency: Quarterly reviews of a minimum of 10 patient accounts processed, from multiple ReGenesis Health Care sites where services from all scopes are rendered.
Review Team: Compliance and Quality Improvement/Assurance teams
Timeline: Begin reviews in Q1 2025.
Responsible Party: Chief Administrative Officer, Chief Financial Officer, Director of Quality Improvement and Risk Management
________________________________________
Monitoring and Evaluation
• Quarterly Reports: Summary of quality control findings shared with leadership.
• Key Performance Indicators (KPIs):
o Reduction in errors in sliding fee application.
o 100% compliance with documentation requirements.
• Audit Follow-Up: Prepare for Operational Site Visit (OSV) to confirm implementation of corrective actions.
• Responsible Party: Chief Administrative Officer, Chief Financial Officer
________________________________________
Communication Plan
• Staff Updates: Regular updates during Leadership and QI/QA team meetings on progress and reminders of proper procedures.
• Leadership Reports: Quarterly updates to the Board of Directors and RHC Executive Team.
________________________________________
Conclusion
ReGenesis Health Care is committed to addressing the identified issues and ensuring compliance with all sliding fee scale policies and guidelines. By implementing the outlined corrective actions, RHC aims to strengthen processes and maintain the highest standards of service for our patients.
If the Department of Health and Human Services has questions regarding this plan, please call Rich Long, CFO, at 564-504-3658.