Condition
Sliding Fee Discounts. Testing performed on the sliding fee discounts charged to patients based on annual gross income and household size, found sliding fee scales to be inappropriately unsupported. The result was patients were given an improper sliding fee discount without documentation t...
Condition
Sliding Fee Discounts. Testing performed on the sliding fee discounts charged to patients based on annual gross income and household size, found sliding fee scales to be inappropriately unsupported. The result was patients were given an improper sliding fee discount without documentation to support that the patient qualified based on their income. In addition, one encounter was given a sliding fee discount tin an amount that did not match their annual gross income and household size resulting in an over charge to the patient. Lack of retaining forms and inaccuracy in the application of the sliding fee program discounts were due to inadequate oversight and review.
Corrective actions
This is a repeat finding from prior fiscal year financial statements. Corrective actions were taken and implemented by March 2, 2022. Corrective action plan from prior year is stated below. Indication of repeat finding was remedied in March of 2022. Each of the findings noted were in fiscal year 2022, however were prior to the corrective action plan of March 2022. Once corrective action plan was implemented, there were no further findings related to the sliding fee discounts. Internal audit process is still in place and continued training to front office is in place.
Corrective Action from prior year finding
Training: Retrain staff on sliding fee policy procedures to ensure (1) income is properly verified, adequately documented and retained and (2) the sliding fee discount is properly determined and applied. All new Front Office staff will receive sliding fee program training as part of their 4-day front office training during onboarding. By Feb 28, 2022, the Front Office Trainer will review documentation requirements around sliding fee scale for patients, including checking applications for completion and making sure the sliding fee applied is being correctly calculated by all Front Office Leads, Supervisors and Center Managers. By Mar 2, 2022, the Front Office Trainer will help create a front office compliance checklist to review front office procedures around documentation, insurance, sliding fees and other programs.
Sliding Fee Annual Update: The Revenue Cycle Director will notify the Applications Team and Front Office trainer each year when the sliding fee scale has been updated. The Applications Team will update the UDS table and map to the calculator in the EHR. The Front Officer trainer will review sliding fee updates on an annual basis update trainings with front office staff and within thirty days of notification of any sliding fee policy revisions.
Internal Audit: An additional level of review will be added to the process to ensure program compliance. The Revenue Cycle Director will create and document a sliding fee scale internal audit process that will be performed monthly. When the audit is performed, findings will be reported to the following: General Cousnel & Compliance Officer, Chief Financial Officer, Chief Operating Officer, Front Officer Trainer, Center Manager, and lead/supervisors. Front Office Trainers will work closely with Center Managers, Leads and Supervisors to ensure that ongoing compliance on sliding fees are met based on internal audit findings. Refresher trainings to staff will be provided based on patterns determined by internal audit findings. This process will be implemented by February 28, 2022.
Name of Contact Person(s) Responsible for Corrective Action: Jaime Allen, Chief Financial Officer
Anticipated Completion Date: March 2, 2022
Update: All corrective actions were implemented as planned and are monitored by the monthly audit led by the Revenue Cycle Director. Front Office trainings continue on a regular basis to mitigate future reoccurrence.