Finding 20381 (2022-001)

Significant Deficiency
Requirement
N
Questioned Costs
-
Year
2022
Accepted
2022-12-04

AI Summary

  • Core Issue: The Center failed to accurately determine sliding fee discounts for two out of thirty-five patients, not aligning with federal poverty guidelines.
  • Impacted Requirements: Compliance with the sliding fee scale and proper documentation processes were not maintained, leading to potential miscalculations of discounts.
  • Recommended Follow-Up: Provide training for registration staff, implement regular supervisory reviews, and conduct internal audits to ensure accurate application of sliding fee discounts.

Finding Text

Item 2022-001 - Special Tests and Provisions U.S Department of Health and Human Services, COVID-19 Health Center Program Cluster (Assistance Listing Number 93.224/93.527) Criteria Health centers are required to have a corresponding schedule of discounts applied and adjusted on the basis of patients' ability to pay and their eligibility. A patient's eligibility to pay is determined on the basis of the official poverty guideline, as revised by DHHS (42 CFR Sections 51c, 107(b)(5), 56.108(b)(5) and 56.303(f)). The Center should be implementing and monitoring procedures to properly determine, calculate and review sliding fee discounts issued to patients in accordance with the Center's sliding fee scale. Statement of Condition While performing our audit, we noted that the Center did not properly determine the sliding fee discount category given to patients selected for testing based on the sliding fee scale in effect for the year ended March 31, 2022. Questioned Costs None Context While performing our audit, we noted that the Center did not properly determine the sliding fee discount category given to two out of thirty-five patients selected for testing based on the sliding fee scale in effect for the year ended March 31, 2022. Cause The condition can be attributed to human error and the lack of internal controls to review and ensure that the proper sliding fee documentation is being maintained and applied. Effect The Center did not comply with the determination of sliding fee discounts based on the federal poverty guidelines in effect for the year ended March 31, 2022. In addition, the Center may not have properly calculated the sliding fee or discount given to the patients and the discount given, if any, may not have been based on the patient's ability to pay. Identification as a Repeat Finding Condition is not a repeat finding. Recommendation We recommend that proper training be given to employees at registration to ensure that the sliding fee discounts are monitored and reviewed by a supervisor on a periodic basis to ensure compliance with the sliding fee scale. In addition, management should conduct internal audits to ensure the sliding fee is calculated properly. Views of Responsible Official The Center concurs with this finding and will ensure that additional controls have been put in place to timely detect system and human errors in the sliding fee discount calculation. The Center will implement additional education to registration staff, improve orientation of new registration staff and strengthen its internal audits to monitor compliance with the sliding fee discount policies and procedures. The Center is also moving to a new Electronic Health Record, EPIC, in November 2022 that should help with ensuring that previous system limitations are no longer an issue.

Corrective Action Plan

CORRECTIVE ACTION PLAN November 4, 2022 Health Resources and Services Administration Tri-County Community Health Council, Inc. (d/b/a CommWell Health) respectfully submits the following corrective action plan for the year ended March 31, 2022. ____________________________________________________________________________________ CohnReznick LLP 1301 Avenue of the Americas New York, NY 10019 Audit Period: March 31, 2022 The findings from the March 31, 2022 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the number assigned in the schedule. FINDINGS ? FEDERAL AWARDS PROGRAM AUDIT U.S. Department of Health and Human Services, COVID-19 Health Centers Program Cluster (Assistance listing number 93.224/93.527) Finding 2022-001 - Special Tests and Provisions SIGNIFICANT DEFICIENCY Recommendation We recommend that proper training be given to employees at registration to ensure that the sliding fee discounts be monitored and reviewed by a supervisor on a periodic basis to ensure compliance with the sliding fee scale. In addition, management should conduct internal audits to ensure the sliding fee is calculated properly. Action Taken CommWell Health concurs with the recommendation and has designed a series of enhancements to existing registration orientation and ongoing training. Additional training time will be dedicated with current front desk registration colleagues to ensure that they can determine household income from the documentation given to them by patients. This education will be completed by December 31, 2022. New hire orientation training will include a thorough review of the Front Desk Handbook and slide fee procedures. Post-test will be given to each front desk colleague upon completion of education. Scores of at least 90% will required or training and testing will be repeated. In addition, CommWell Health is moving to a new electronic health record (EHR), EPIC, beginning November 7, 2022. This system has much better controls built in to help ensure that slide fee is documented correctly. EPIC also does not have many of the system limitations our previous EHR had. Audits of 100% of slide fee records will be done every day by designated colleagues to ensure slide fee documentation is correct. Supervisors will review daily audit findings and ensure additional training is given accordingly. Corrective action will be taken on any errors noted during audits. Finance staff will conduct random internal audits of slide fee records each month to evaluate for compliance with applicable requirements. Results of internal audits will be reviewed monthly in Utilization Review Committee. If the Health Resources and Services Administration has questions regarding this plan, please call Cheryl Stanley, Chief Financial Officer, at 910-567-7008.

Categories

Special Tests & Provisions Subrecipient Monitoring Eligibility Internal Control / Segregation of Duties

Other Findings in this Audit

  • 20382 2022-001
    Significant Deficiency
  • 20383 2022-001
    Significant Deficiency
  • 596823 2022-001
    Significant Deficiency
  • 596824 2022-001
    Significant Deficiency
  • 596825 2022-001
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
93.527 Grants for New and Expanded Services Under the Health Center Program $9.46M
93.224 Consolidated Health Centers (community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) $1.75M
93.498 Provider Relief Fund and American Rescue Plan (arp) Rural Distribution $1.46M
93.153 Coordinated Services and Access to Research for Women, Infants, Children, and Youth $408,457
93.918 Grants to Provide Outpatient Early Intervention Services with Respect to Hiv Disease $329,179
10.557 Special Supplemental Nutrition Program for Women, Infants, and Children $167,118
93.917 Hiv Care Formula Grants $16,839
93.461 Hrsa Covid-19 Claims Reimbursement for the Uninsured Program and the Covid-19 Coverage Assistance Fund $2,456