Ineffective Controls Over the Sliding Fee Scale Eligibility Requirements
Condition
Community Health Concern, Inc. (“CHC”) did not effectively maintain an internal control system over its sliding fee and clinic service eligibility requirements. During the compliance testing of the Uniform Guidance
“...
Ineffective Controls Over the Sliding Fee Scale Eligibility Requirements
Condition
Community Health Concern, Inc. (“CHC”) did not effectively maintain an internal control system over its sliding fee and clinic service eligibility requirements. During the compliance testing of the Uniform Guidance
“Special Tests and Provisions – Sliding Fee Applications” requirements, we noted:
• Two (2) patient files/charts did not have the required eligibility information, including sliding fee
scale assessments, proof of income, general consent, registration form, etc.
• A Medicare patient was assessed a sliding fee scale discount for services that should have been
charged to Medicare.
Management’s Views:
CHC implemented a new electronic health record (EHR), Epic Platform, in October 2023 to replace its 15-year-old legacy system, Intergy. After one year of extensive training, CHC with the assistance of Health Choice Network (HCN), a Health Center Controlled Network, rollout the Epic Platform, During and post implementation of the new platform, CHC encountered significant challenges in its front desk operations (e.g. eligibility information, including registration form, general consent, proof of income and sliding fee scale assessments), hence, two patients’ charts did not cross over from the old system to the new platform and challenges with our outreach teams’ encounters. Also, a Medicare beneficiary was incorrectly assessed a sliding fee scale discount for services that should have been charged to Medicare. As a result of the audit findings, we have identified several areas for improvements to enhance the effectiveness and efficiency of our front desk and outreach teams processes.
Corrective Action Plan:
The following corrective action plan outlines the necessary steps to address these areas:
1. Monthly Chart Audit by the Lead Patient Services Representative (Lead PSR):
• Checklist to include:
o Eligibility verification
o Consent to treat
o Registration packet
o Sliding Fee Application
o Self-declaration
2. Utilization of HCN Teams Chat Tool
• Leverage the HCN Teams chat for addressing insurance-related questions, such as duplicate commercial plans, to ensure accurate and timely responses. 3. Retraining Low Performing Staff
• Low-performing staff will undergo retraining with the Lead PSR and HCN Revenue Cycle Management consultants to enhance their performance and understanding of the processes.
4. Competency Test Development
• Develop and implement a competency test for PSRs to ensure all team members possess the required knowledge and skills.
5. Monthly Meetings
• Hold monthly meetings between the PSR and Billing teams to share knowledge, address concerns, and promote continuous learning and improvement.
6. Staff Registration Limitation
• Limit the number of staff able to register patients. PSRs will take the lead role in registration, with MAs serving as backup when necessary.
7. Creation of Insurance Quick-Guides
• Create quick-guides to aid in the selection and verification of insurance, ensuring staff have easy access to essential information.
8. Hard Stops on EPIC workflow
• Request hard stops on EPIC for the input of key information to prevent incomplete or incorrect data entry, thereby improving data integrity and patient care.
Anticipated Date of Completion:
Management has implemented approximately 80% of the strategies described in the Plan above.
These corrective actions are designed to address the identified issues and enhance the efficiency and accuracy of the registration and billing processes. Management believes that these measures will also lead to significant improvements in the overall operations and patient satisfaction. Management anticipates the successful completion date for the entire Plan to be no later than August 31st, 2024.
Contact Person:
For inquiries regarding this finding, please contact Benjo Reyes at BenjoR@CamillusHealth.org who is responsible for the corrective actions.