Finding 12166 (2022-001)

Significant Deficiency
Requirement
N
Questioned Costs
-
Year
2022
Accepted
2022-12-06
Audit: 16269
Organization: Marana Health Center, INC (AZ)

AI Summary

  • Core Issue: There is a significant deficiency in internal controls related to the calculation of sliding fee discounts for patients.
  • Impacted Requirements: Compliance with federal regulations requiring accurate fee schedules and discounts based on patients' ability to pay.
  • Recommended Follow-Up: Implement a second-level independent review process for demographic and income data in the billing system to ensure accuracy.

Finding Text

2022-001: Significant Deficiency in Internal Control Over Compliance and Compliance Over Application of Sliding Fee Discounts Federal Agency: U.S. Department of Health and Human Services Federal Program Title: Health Centers Cluster CFDA Number: 93.224 and 93.527 Criteria: The Health Centers Program, 42 U.S.C. ? 245b(k)(3)(G)(i) states that ?the center has prepared a schedule of fees or payments for the provision of its services consistent with locally prevailing rates or charges and designed to cover its reasonable costs of operation and has prepared a corresponding schedule of discounts to be applied to the payment of such fees or payments, which discounts are adjusted on the basis of the patient?s ability to pay.? Condition: During our testing of sliding fee discounts for health center, there were two instances in which the sliding fee was calculated incorrectly. Context: We randomly selected twenty-five sliding fee discounts to test for compliance. Two of the twenty-five sliding fee selections was incorrectly calculated. Questioned Costs: None Cause: The clinic entered the patient?s salary amount incorrectly in the billing system. There is not a system in place to properly detect and identify slides that may be incorrectly entered or applied. Effect: The patient may not receive the discount they are eligible for and noncompliance with Federal requirements and terms of the grant which may result in withdrawal or revocation of the grant given by the Federal agency. Recommendation: Management?s close supervision and review is the best means to ensure all requirements are met. We recommend implementation of a second level independent review over the demographic data and income verification information entered into the patient billing system in order to ensure the financial classification is correct.

Corrective Action Plan

Marana Health Center, Inc. respectfully submits the following corrective action plan for the year ended June 30, 2022. Audit Period: July 1, 2021 - June 30, 2022 Category: GENERAL MARANA HEALTH CENTER, INC. AD-2-010 Procedure: Sliding Fee Schedule Patient Demographic Changes Page 1 of 2 I. PURPOSE: The Sliding Fee Schedule (SFS) Patient Demographic Changes process was created to ensure any patient who is certified on MHC Healthcare's (MHC) SFS and has changes on their Patient Profile (Profile) to their Family Size and/or Income are referred to the Outreach Department (OR) and that these changes are only made by an OR employee or the OR Manager. II. PROCESSES: A. Front Office (FO) staff print Profiles from the Electronic Health Record (EHR) for all patient appointments, which allows patients to make required changes to their demographics on file. This includes Family Size and/or Income. When a patient on MHC's SFS notifies FO of changes to the aforementioned demographics, the patient must be referred to the MHC OR Department for further review. Only OR staff may make these demographic changes in the EHR for SFS Patients. Ill. PROCEDURES: A. FO staff will print a Profile for all patient appointments. 1. FO will ensure all patients review the Profile for required changes to their demographics in the EHR system. a. If the patient is on the SFS and notates any changes required on the Profile to be made to their Family Size and/or Income, the FO will: 1) Immediately notify the health center's assigned OR employee that a patient in the office for an appointment has required changes to these demographics. a) Notification can be made via telephone or a Teams message. b) If the site does not have an assigned OR employee, notification will be made to the OR Manager. 2) The OR employee will respond to FO: a) The patient is placed on the OR schedule for an immediate appointment while the patient is in the health center and available, either prior to or after the clinical visit, depending on allowable time. b) An appointment will be scheduled while the patient is in the health center for a later date to review changes and the possible affect these changes may have on the patient's SFS certification and/or SFS tier. c) The patient is contacted via telephone by the OR employee to schedule an appointment to review the possible changes to the patient's SFS certification and/or SFS tier. d) When scheduling the appointment, the patient may schedule it at the Health Center or choose to have this appointment via telehealth. 3) Only OR employees may change the Family Size and/or Income demographics in the EHR for SFS patients. a) FO will make all necessary demographic changes in the EHR, excluding Family Size and/or Income. b. FO will scan the Profile into the EHR and forward a copy to the appropriate OR employee. 2. The OR Manager will ensure that FO staff have a current list of OR employees, along with appropriate contact information and location. Category: GENERAL MARANA HEALTH CENTER, INC. AD-2-010 Procedure: Sliding Fee Schedule Patient Demographic Changes Page 2 of 2 3. The OR Manager will immediately communicate any deviations to this policy and procedure to the assigned Associate Director of Integrated Operations (ADIO) when noted. IV. REFERENCES: Sliding Fee Schedule V. ATTACHMENTS: None Approved: Original Approval: 09/2022 9/28/2022 Date 9/28/2022 Date Reviewed/Revised: Responsible Party: Director, Integrated Operations If the Department of Health and Human Services has questions regarding this plan, please call Tamie Olson, CFO at (520) 784-8655.

Categories

Significant Deficiency Internal Control / Segregation of Duties

Other Findings in this Audit

  • 12167 2022-001
    Significant Deficiency
  • 12168 2022-001
    Significant Deficiency
  • 588608 2022-001
    Significant Deficiency
  • 588609 2022-001
    Significant Deficiency
  • 588610 2022-001
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
10.766 Community Facilities Loans and Grants $8.68M
93.224 Consolidated Health Centers (community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) $4.81M
93.527 Affordable Care Act (aca) Grants for New and Expanded Services Under the Health Center Program $3.30M
10.557 Special Supplemental Nutrition Program for Women, Infants, and Children $981,937
32.006 Covid-19 Telehealth Program $794,998
93.268 Immunization Cooperative Agreements $168,971
93.137 Community Programs to Improve Minority Health Grant Program $21,265
93.778 Medical Assistance Program $12,766