Finding 1032 (2023-002)

Significant Deficiency
Requirement
N
Questioned Costs
-
Year
2023
Accepted
2023-10-31
Audit: 1956
Organization: Milwaukee Health Services, Inc. (WI)
Auditor: Wipfli LLP

AI Summary

  • Core Issue: Milwaukee Health Services did not consistently apply its sliding fee discount schedule, leading to potential incorrect charges for patients.
  • Impacted Requirements: Compliance with the sliding fee policy is essential to ensure patients are charged accurately based on their income.
  • Recommended Follow-Up: Review and enhance policies and controls for calculating fees to align with the sliding fee policy and monitor compliance.

Finding Text

Finding 2023 002: Sliding Fee CFDA Title: Health Center Cluster Assistance Listing Number: 93.224 Federal Award Year: 2/1/22 1/31/23 Federal Agency: U.S. Department of Health and Human Services Criteria Health centers must prepare and apply a sliding fee discount schedule (SFDS) so that the amounts owed for health center services by eligible patients are adjusted (discounted) based on the patient’s ability to pay. Condition Wipfli reviewed 40 sliding fee charges to test if the amount charged, was calculated properly based on the patients’ income level and in compliance with Milwaukee Health Services’ sliding fee policy. Wipfli noted that 2 of the charges were not properly determined or information was not retained to determine if the charge was properly determined. Questioned Costs Undetermined. Cause and Effect Milwaukee Health Services, Inc. did not consistently follow the Organization’s policies for documenting and calculating charges for services when using the sliding fee scale. Patients may be charged the improper amount if proper procedures and controls are not in place to ensure the sliding fee is applied in accordance with Milwaukee Health Services’ sliding fee policy. Auditor’s Recommendation Review policies and implement and monitor controls surrounding the determination of the fees charged to patients to determine that fees are being determined in accordance with Milwaukee Health Services’ sliding fee policy. View of Responsible Officials Management agrees with the findings and has committed to a corrective action plan.

Corrective Action Plan

Milwaukee Health Services, Inc. ("MHSI") submits the following corrective action plan for all identified findings and questioned costs for the year ending January 31, 2023. Finding 2023-002: Sliding Fee: External auditors reviewed 40 sliding fee charges to test if the amount charged, was calculated properly based on the patients’ income level and in compliance with Milwaukee Health Services’ sliding fee policy. External auditors noted that 2 of the charges were not properly determined or information was not retained to determine if the charge was properly determined. Corrective Action: HRSA performed a site visit regarding the 330 Grant in May 2023. During that site visit, the Sliding Fee Discount program requirement was classified as “met”. The audited timeframe for this fiscal year was during the period when we transitioned, on June 21, 2023, from the Centricity Electronic Health Record (EHR) to the OCHIN Epic EHR. Of the 40 Sliding Fee charges tested, there were 2 failures. Both failures were from charges selected in the Centricity EHR. No fails were identified in the OCHIN Epic EHR, which has built in safeguards to assist in Sliding Fee calculation accuracy. Responsible current staff have been re-trained, and new staff are being trained as part of the on-boarding process. 100% of Sliding Fee accounts will be audited from February 1, 2023, and forward. Any required corrections will be made immediately. Any impacted accounts will be appropriately reprocessed when identified. All forms related to Sliding Fee determination will be scanned into the OCHIN Epic system and will be reviewed for quantity and quality, prior to disposing of any paper copies. Person Responsible for Corrective Action: Chief Financial Officer (Laurie Yake), Revenue Cycle Director (Leeann Stoiber) Anticipated Timing for Completion of Corrective Action: November 30, 2023.

Categories

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Other Findings in this Audit

  • 577474 2023-002
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
93.224 Consolidated Health Centers (community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) $4.33M
10.557 Special Supplemental Nutrition Program for Women, Infants, and Children $459,118
93.918 Grants to Provide Outpatient Early Intervention Services with Respect to Hiv Disease $438,314
93.526 Affordable Care Act (aca) Grants for Capital Development in Health Centers $186,752