Finding 2170 (2023-001)

Significant Deficiency Repeat Finding
Requirement
N
Questioned Costs
-
Year
2023
Accepted
2023-11-20
Audit: 3746
Auditor: Cohnreznick LLP

AI Summary

  • Core Issue: The Center inaccurately applied sliding fee discounts, failing to follow its own policy.
  • Impacted Requirements: This non-compliance affects adherence to federal guidelines for patient eligibility and discount calculations.
  • Recommended Follow-Up: Implement stronger internal controls to ensure accurate calculations of sliding fee discounts based on family size and income.

Finding Text

Finding 2023.001: Sliding Fee Scale Documentation Grantor: U.S. Department of Health and Human Services Federal Program Names: Health Center Program Cluster Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care), COVID-19 Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care), Grants for New and Expanded Services Under the Health Center Program COVID-19 Grants for New and Expanded Services Under the Health Center Program Federal Assistance Listing Numbers: 93.224 and 93.527 Compliance Requirement: Special Tests and Provisions 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. Condition The Center did not always apply the sliding fee discount accurately based on the Center's sliding fee discount policy. Cause The Center did not have adequate internal controls in place to effectively ensure that all sliding fee discounts were properly calculated based on approved documentation. Effect The Center did not comply with the appropriate rules and regulations as per the Uniform Guidance. Questioned Costs None. Context A test of 40 discount transactions was performed and resulted in one instance of a sliding fee discount not being properly calculated based on the respective patient family size and income. Our sample was a statistically valid sample. Identification of Repeat Finding Yes - 2022.001. Recommendation The Center should establish a system of internal controls to ensure that all sliding fee discounts are properly calculated based on family size and income. Views of Responsible Officials Management agrees with the audit finding and will strengthen internal controls and accountability to correct the deficiency.

Corrective Action Plan

October 5, 2023 To: United States Department of Health and Human Services Generations Family Health Center, Inc. respectfully submits the following corrective action plan for the year ended June 30, 2023. CohnReznick LLP 350 Church Street Hartford, CT 06103 Audit Period: June 30, 2023 The findings from the June 30, 2023 schedule of findings and questioned costs are discussed below. The finding is numbered consistently with the numbers assigned in the schedule. FINANCIAL STATEMENT FINDINGS: Finding 2023.001- Sliding Fee Scale Documentation Recommendation The Center should establish a system of internal controls to ensure that all sliding fee discounts are properly calculated based on family size and income. Action Taken: Upon review of the finding, it was determined that the system calculated the slide correctly, but the procedure code was assigned to the incorrect procedure class, creating the error. Beginning July 1, 2023, Management has: • Reviewed the entire fee schedule, schedule of discounts and procedure groupings in the practice management system compared to the board approved fee schedule. Only one procedure group required correction of one procedure code. • In addition, the Director of Patient Revenue will work with the Electronic Health Record vendor to organize the system procedure classes for all procedure codes and financial classes to decrease any crosswalk issues or redundancies. In addition, the Director of Patient Revenue will work with the EHR vendor to upload fee schedules and sliding fee discount groups electronically. Previous internal controls adopted include: • Upon creating adding a new charge to the system, the Director of Patient Revenue posts the charge into a test patient account to confirm that the standard and slide rates match those entered on the fee schedule • At the annual review and/or revision of the Agency’s fee schedule, the Billing Manager assists the Director of Patient Revenue in reviewing every charge on the updated/approved year’s fee schedule to confirm the rates and slide assignment match the Fee Schedule. • A quarterly audit of insured and self-pay patients occur to review that adjustments are correct per agency policy. This action decreases chances of system issues that cause erroneous adjustments going unnoticed. If the Cognizant or Oversight Agency for Audit has questions regarding this plan, please call: Debra Savoie, CFO at (860) 456-6271.

Categories

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

Other Findings in this Audit

  • 2171 2023-001
    Significant Deficiency Repeat
  • 2172 2023-001
    Significant Deficiency Repeat
  • 2173 2023-001
    Significant Deficiency Repeat
  • 2174 2023-001
    Significant Deficiency Repeat
  • 578612 2023-001
    Significant Deficiency Repeat
  • 578613 2023-001
    Significant Deficiency Repeat
  • 578614 2023-001
    Significant Deficiency Repeat
  • 578615 2023-001
    Significant Deficiency Repeat
  • 578616 2023-001
    Significant Deficiency Repeat

Programs in Audit

ALN Program Name Expenditures
93.527 Affordable Care Act (aca) Grants for New and Expanded Services Under the Health Center Program $2.46M
93.498 Provider Relief Fund $642,198
93.918 Grants to Provide Outpatient Early Intervention Services with Respect to Hiv Disease $263,099
93.268 Immunization Cooperative Agreements $189,955
93.224 Consolidated Health Centers (community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) $139,557
93.526 Affordable Care Act (aca) Grants for Capital Development in Health Centers $116,453
93.153 Coordinated Services and Access to Research for Women, Infants, Children, and Youth $34,080
93.994 Maternal and Child Health Services Block Grant to the States $32,192