Corrective Action Plans

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1. Quarterly Review Process: The Compliance Committee of the Board will continue to review provider credentialing and privileging files at least quarterly. These reviews will be documented in committee meeting minutes and retained for audit readiness.
1. Quarterly Review Process: The Compliance Committee of the Board will continue to review provider credentialing and privileging files at least quarterly. These reviews will be documented in committee meeting minutes and retained for audit readiness.
2. Policy Review and Revision: SCMRC will re-evaluate its Credentialing and Privileging Policy during the next scheduled policy review cycle to determine whether full Board approval should be incorporated in alignment with HRSA best practices.
2. Policy Review and Revision: SCMRC will re-evaluate its Credentialing and Privileging Policy during the next scheduled policy review cycle to determine whether full Board approval should be incorporated in alignment with HRSA best practices.
3. Credentialing Log Maintenance: The Compliance Officer will maintain a centralized credentialing and privileging log that includes primary source verifications, privilege grant dates, and expiration tracking.
3. Credentialing Log Maintenance: The Compliance Officer will maintain a centralized credentialing and privileging log that includes primary source verifications, privilege grant dates, and expiration tracking.
4. Internal Audit and Quality Checks: SCMRC will conduct semi-annual internal audits of credentialing files to ensure documentation accuracy and compliance with HRSA Chapter 5 requirements.
4. Internal Audit and Quality Checks: SCMRC will conduct semi-annual internal audits of credentialing files to ensure documentation accuracy and compliance with HRSA Chapter 5 requirements.
5. Board Training: The Compliance Committee and Board members will receive annual refresher training on credentialing oversight responsibilities, file requirements, and regulatory expectations.
5. Board Training: The Compliance Committee and Board members will receive annual refresher training on credentialing oversight responsibilities, file requirements, and regulatory expectations.
1. All CMS-838 Credit Balance Reports for the audit period and subsequent quarters were submitted in September 2024 and accepted by CMS.
1. All CMS-838 Credit Balance Reports for the audit period and subsequent quarters were submitted in September 2024 and accepted by CMS.
2. SCMRC updated its Medicare compliance protocols in 2025 and established centralized tracking of required federal reports in the CEO’s compliance calendar.
2. SCMRC updated its Medicare compliance protocols in 2025 and established centralized tracking of required federal reports in the CEO’s compliance calendar.
3. Ongoing Medicare reporting oversight has been assigned to the Controller, with CEO review and incorporation into Board-level financial and compliance workplans.
3. Ongoing Medicare reporting oversight has been assigned to the Controller, with CEO review and incorporation into Board-level financial and compliance workplans.
1. Maintain documentation of CMS guidance confirming discontinuation of the CMS-838 reporting requirement.
1. Maintain documentation of CMS guidance confirming discontinuation of the CMS-838 reporting requirement.
2. Continue centralized tracking of Medicare-related reporting requirements through the CEO’s compliance calendar.
2. Continue centralized tracking of Medicare-related reporting requirements through the CEO’s compliance calendar.
3. Ensure that changes in federal reporting requirements are verified, documented, and reviewed by the Controller and CEO.
3. Ensure that changes in federal reporting requirements are verified, documented, and reviewed by the Controller and CEO.
4. Reinforce Medicare compliance responsibilities in SCMRC’s financial and operational planning processes.
4. Reinforce Medicare compliance responsibilities in SCMRC’s financial and operational planning processes.
5. Conduct periodic internal reviews to ensure no reportable credit balances exist, even if formal reports are no longer required.
5. Conduct periodic internal reviews to ensure no reportable credit balances exist, even if formal reports are no longer required.
Corrective Actions Taken:
Corrective Actions Taken:
1. The overdue Medicare Cost Report for FYE 2021 was filed and accepted by CMS on July 18, 2024.
1. The overdue Medicare Cost Report for FYE 2021 was filed and accepted by CMS on July 18, 2024.
2. A centralized compliance calendar was developed and is maintained by the CEO to track all federal, state, and grant-related deadlines.
2. A centralized compliance calendar was developed and is maintained by the CEO to track all federal, state, and grant-related deadlines.
3. Oversight of the Medicare Cost Report was formally assigned to the CEO and incorporated into SCMRC’s internal and board planning processes.
3. Oversight of the Medicare Cost Report was formally assigned to the CEO and incorporated into SCMRC’s internal and board planning processes.
4. Medicare Cost Report deadlines are reviewed monthly during Finance Committee meetings to ensure accountability.
4. Medicare Cost Report deadlines are reviewed monthly during Finance Committee meetings to ensure accountability.
5. SCMRC leadership received training in 2024 on CMS reporting requirements and nonprofit compliance timelines.
5. SCMRC leadership received training in 2024 on CMS reporting requirements and nonprofit compliance timelines.
6. SCMRC engaged Allen Bryant, CPA, to support timely Medicare Cost Report preparation and submission going forward.
6. SCMRC engaged Allen Bryant, CPA, to support timely Medicare Cost Report preparation and submission going forward.
7. SCMRC’s updated compliance tracking system was reviewed during the 2025 HRSA Verification Site Visit, contributing to the clearance of Chapter 18 conditions.
7. SCMRC’s updated compliance tracking system was reviewed during the 2025 HRSA Verification Site Visit, contributing to the clearance of Chapter 18 conditions.
Corrective Action Plan:
Corrective Action Plan:
1. Maintain the centralized compliance calendar with documented Medicare Cost Report deadlines, reviewed monthly.
1. Maintain the centralized compliance calendar with documented Medicare Cost Report deadlines, reviewed monthly.
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