Program: COVID-19 Health Center Program Cluster
Assistance Listing No.: 93.224
Federal Grantor: U.S. Department of Health and Human Services
Passed-through: N/A
Award No. and Year: Various
Compliance Requirements: Special Tests and Provisions
Type of Finding: Material Weakness in Internal Control ov...
Program: COVID-19 Health Center Program Cluster
Assistance Listing No.: 93.224
Federal Grantor: U.S. Department of Health and Human Services
Passed-through: N/A
Award No. and Year: Various
Compliance Requirements: Special Tests and Provisions
Type of Finding: Material Weakness in Internal Control over Compliance and Material Non-Compliance
Department’s Management Response:
Health Care Agency (HCA) management agrees with the recommendation to strengthen the established
policies and procedures to ensure that the sliding fee discount program schedules are applied to patient
charges consistent with its sliding fee discount schedule, and to ensure that County personnel strictly
adheres to policies and procedures.
View of Responsible Officials and Corrective Action:
HCA management recognizes that the sliding fee discount schedule/discount grid established in 2020 was
complex and may have contributed to errors in adjustments. A new fee schedule was developed in 2023 to
establish flat fees that are more inclusive of services. The grid established in 2020 was in effect until the
new grid was approved by the Board of Supervisors on March 15, 2023. Most of the encounters selected
for review were encounters dated prior to the new grid’s effective date.
HCA management has strengthened its sliding fee policy and procedure, approved by the Board of
Supervisor on March 15, 2023. HCA management will implement the following internal control process
to ensure that adjustments are consistent with the sliding fee discount program fee schedule:
1. All Medical Billing Specialists responsible for enrolling patients into the sliding fee program will
be retrained on eligibility and adjustments.
2. To ensure that patients have received the correct adjustment, we will run a report of all patients
under the sliding fee program with at least one encounter, year to date. All applications, proof of
income, program eligibility, and adjustments will be reviewed for each patient. Corrections will be
made, if applicable.
3. For the remaining of FY 22/23, a monthly report of all encounters under the sliding fee discount
program will be pulled and reviewed monthly for accuracy. Corrections will be made and staff will
be trained, as needed.
4. Starting in FY 23/24, a random sampling of sliding fee discount program encounters per Federally
Qualified Health Center will be audited monthly to ensure accuracy and timely adjustment of
encounters. Results will be trended to address any additional process improvements.
COUNTY OF VENTURA, CALIFORNIA
CORRECTIVE ACTION PLAN
FOR THE YEAR ENDED JUNE 30, 2023
6
Name of Responsible Persons:
Lizeth Barretto, Ambulatory Care COO – Ms. Barretto will ensure that the activities listed in the Corrective
Action Plan are executed until an Ambulatory Care CFO and/or Ambulatory Care Patient Revenue Manager
is hired.
Ambulatory Care CFO (Vacant) – Establishes sliding fee discount program policy, procedures, and fee
schedules.
Ambulatory Care Patient Revenue Manger (Vacant) – Responsible for the oversight of the Medical Billing
Specialists responsible for sliding fee discount eligibility and adjustments.
Implementation Date:
April 15, 2024, Training of Medical Billing Specialists and monthly encounter review and corrections.
April 22, 2024, Year to date report and internal audit
August 5, 2024, Monthly sampling of encounters