Finding 1172140 (2025-001)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2025
Accepted
2026-02-03
Audit: 385267
Organization: Marin Community Clinics, Inc. (CA)

AI Summary

  • Core Issue: Some patients received sliding fee discounts that did not match the organization's policy.
  • Impacted Requirements: This violates specific regulations regarding sliding fee discounts as outlined in federal law.
  • Recommended Follow-Up: Management should enhance training for staff on the sliding fee policy and implement procedures to ensure compliance.

Finding Text

Health Center Program Cluster Assistance Listing Numbers 93.224 and 93.527 U.S. Department of Health and Human Services Criteria or Specific Requirement – Special Tests and Provisions: Sliding Fee Discounts (42 USC 254(k)(3)(g); 42 CFR sections 51c.303(g); and 42 CFR sections 56.303 (f)) Condition – Patients received a sliding fee discount that was inconsistent with the stated sliding fee discount categories under the Organization’s policy. Questioned cost – None Context – A sample of 40 encounters were tested out of the total population of 245,999 encounters. The sampling methodology used is not and is not intended to be statistically valid. Five patients received a sliding fee adjustment that was inconsistent with the approved policy for the proper sliding fee adjustments based on their income documentation. Effect or potential effect – Sliding fee balances of the patients were inconsistent with the Organization’s sliding fee discount policy. Cause – The Organization did not comply with their sliding fee policy. Identification as a repeat finding, if applicable – Yes. Finding 2024-001. Recommendation – We recommend management continue to train personnel and ensure all personnel understand the sliding fee scale policy and adhere to the requirements and guidelines set forth in the policy. Procedures should be implemented to ensure that eligible patients receive discounts in accordance with the sliding fee scale and the Health Center Program Compliance Manual.

Corrective Action Plan

1. Hire a Revenue Cycle Liaison o Designate a dedicated Revenue Liaison who will serve as the primary trainer and subject matter expert for the Sliding Fee Discount Program under the Revenue Cycle Director. o Responsibilities include developing training materials, conducting onboarding sessions, and serving as the point of contact for SFDP-related questions. o Estimated Time of Completion: • 1–2 weeks for interviews and selection • 2–3 weeks for onboarding, access setup, and curriculum review • Liaison fully functional by mid-January 2026 2. Immediate Staff Retraining o Retrain all staff involved in SFDP on program requirements, eligibility criteria, and correct implementation of sliding fee determination and billing. o Training will include real-world scenarios, documentation standards, and compliance checkpoints to ensure accuracy. o Quarterly training will be conducted for all Clinic Managers, Front Office staff and Call Center staff. o The topics at these courses covered: i. The overall philosophy and purpose of collecting accurate data. ii. Definition of income; how to accurately calculate income. iii. Definition of family size / household. iv. The call center role in scheduling the patient appointments and how to set the document expectations. v. The importance of collecting all necessary forms and documents from patients in order to insert their financial status into MCC sliding fee scale. vi. How to enter accurate information into all the applicable forms in the EHR. vii. Operational workflow. o Estimated Time of Completion • Retraining will start after the Liaison is fully operational. • Retraining Start: Early to Mid-February 2026 • Retraining Completion: Late February 2026 3. Periodic Compliance Audits o Compliance department will perform independent audits of SFDP transactions on a quarterly basis. o Findings will be reported to senior leadership and incorporated into compliance risk assessments. o Findings will be used for ongoing training and process improvement across all clinics. o Estimated Time of Completion • First audit period: January–March 2026 • Report delivered: April 2026 4. Ongoing Staff Retraining Based on Audit Outcomes o Use audit results to identify gaps and retrain staff accordingly. o Maintain a continuous improvement cycle to ensure adherence to SFDP policies and minimize errors. o Estimated Time of Completion • First audit period: January–March 2026 • Report delivered: April 2026 5. Monthly Peer review o Each supervisor will review a random sample of applications from a different clinic (not their own). o Any discrepancies will be corrected promptly and communicated to the originating clinic. o Results will be tracked monthly to identify trends and target training needs. o Estimated start date will be in March 2026 o The result will be assessed to determine the duration of this review. Responsible- Multiple team members share responsibility for accurately documenting and preserving these records in the correct patient charts. This includes the Clinic Manager, Front Office Supervisors, and the Director of Revenue Cycle. Ultimately, MCC views this as a measure that the Chief Financial Officer and Director of Revenue Cycle all hold responsibility to ensure this policy is adhered to closely. Contact person for Corrective Action Plan listed above: Bharatha Naotunne, CFO Email: bnaotunne@marinclinic.org

Categories

Special Tests & Provisions

Other Findings in this Audit

  • 1172138 2025-001
    Material Weakness Repeat
  • 1172139 2025-001
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
93.224 HEALTH CENTER PROGRAM (COMMUNITY HEALTH CENTERS, MIGRANT HEALTH CENTERS, HEALTH CARE FOR THE HOMELESS, AND PUBLIC HOUSING PRIMARY CARE) $2.99M
10.569 EMERGENCY FOOD ASSISTANCE PROGRAM (FOOD COMMODITIES) $524,249
93.527 GRANTS FOR NEW AND EXPANDED SERVICES UNDER THE HEALTH CENTER PROGRAM $48,334
93.767 CHILDREN'S HEALTH INSURANCE PROGRAM $48,228
93.527 COVID-19 - Health Center Program $16,865
93.917 HIV CARE FORMULA GRANTS $11,891