Finding 22735 (2022-001)

Significant Deficiency
Requirement
E
Questioned Costs
$1
Year
2022
Accepted
2023-03-09
Audit: 19423
Organization: University of Colorado Health (CO)

AI Summary

  • Core Issue: UCHealth received $50,808.16 in HRSA funds for a COVID-19 patient who was later found to have retroactive Medicaid coverage, making them ineligible for the program.
  • Impacted Requirements: The program requires that patients treated must not have insurance coverage at the time of service, which was not effectively monitored.
  • Recommended Follow-Up: UCHealth should implement a formal process to verify patient insurance status, including checks for retroactive coverage, before seeking reimbursement.

Finding Text

ALN, Federal Agency, and Program Name - 93.461, Department of Health and Human Services, Health Resources and Services Administration (HRSA), HRSA COVID-19 Claims Reimbursement for the Uninsured Program and the COVID-19 Coverage Assistance Fund Federal Award Identification Number and Year - N/A Finding Type - Significant deficiency and material noncompliance with laws and regulations Repeat Finding - No Criteria - The terms and conditions of the program allow payment to recipients to provide care or treatment related to positive diagnoses of COVID-19 for uninsured individuals. Condition - UCHealth treated a patient with COVID-19 who did not have insurance at the time of service. The patient subsequently applied for and received coverage under Medicaid, with a retroactive coverage effective date prior to the date of service. UCHealth's process failed to identify the patient's subsequent retroactive insurance coverage, and UCHealth received reimbursement under the program. Questioned Costs - $50,808.16 Identification of How Questioned Costs Were Computed - Questioned costs were determined based on the HRSA funds received for the insured patient. Context - During fiscal year 2022, 60 patients were selected for eligibility testing. Of the 60, 1 patient subsequently applied for and received coverage under Medicaid and, therefore, was not eligible under the program. Cause and Effect - An effective control was not in place to ensure that patients who received treatment were not covered by insurance and, therefore, eligible under the program. This resulted in UCHealth receiving HRSA funds for services provided to a patient who had insurance effective at the time of service. Recommendation - UCHealth should establish a formal process to ensure patients treated under the program do not have insurance coverage at the time of service, including a process to identify patients who subsequently receive insurance coverage that is retroactively effective on the date of service prior to seeking reimbursement under the program. Views of Responsible Officials and Corrective Action Plan - UCHealth reviewed the account in question. Emergency Medicaid was found and attached to the account, and a full refund to HRSA COVID-19 was processed on February 1, 2023 in the amount of $50,808.16 on check #431627. Review of the account demonstrated that system actions identified the correct Medicaid coverage and flagged for manual review. User error was made on consecutive days where Medicaid was not properly added to the account. Financial Counseling and Business Services leadership have reinforced coverage attachment protocols with staff on February 24, 2023.

Corrective Action Plan

Condition: During testing of CFDA 93.461 HRSA COVID-19 Uninsured Program the auditor identified one eligibility finding related to a patient selected for testing who was uninsured at the time of service, but the patient subsequently applied for and received coverage under Medicaid with a retroactive coverage effective date prior to the date of service. UCHealth should have controls and processes in place to identify retroactive insurance coverage for patients treated under the program to ensure HRSA reimbursement is not received for patients with insurance coverage. Planned Corrective Action: This account was reviewed. Emergency Medicaid was found and attached to the account and a full refund to HRSA COVID-19 was processed on 2/1/2023 in the amount of $50,808.16 on check #431627. Review of the account demonstrated that system actions identified the correct Medicaid coverage and flagged for manual review. User error was made on consecutive days where Medicaid was not properly added to the account. Financial Counseling and Business Services leadership have reinforced coverage attachment protocols with staff 2/24/2023. Contact person responsible for corrective action: Michael Bishop Anticipated Completion Date: 2/1/2023

Categories

Questioned Costs Cash Management Eligibility Significant Deficiency

Other Findings in this Audit

  • 599177 2022-001
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
93.498 Covid-19 - Provider Relief Fund and American Rescue Plan (arp) Rural Distribution $26.52M
93.461 Covid-19 - Hrsa Covid-19 Claims Reimbursement for the Uninsured Program and the Covid-19 Coverage Assistance Fund $13.27M
93.917 Hiv Care Formula Grants $254,668
16.588 Violence Against Women Formula Grants $214,407
93.395 Cancer Treatment Research $47,001
93.914 Hiv Emergency Relief Project Grants $37,039
93.324 State Health Insurance Assistance Program $25,290
93.243 Substance Abuse and Mental Health Services_projects of Regional and National Significance $25,259
20.600 State and Community Highway Safety $18,914
93.846 Arthritis, Musculoskeletal and Skin Diseases Research $18,810
32.006 Covid-19 - Telehealth Program $15,687
10.561 Covid-19 - State Administrative Matching Grants for the Supplemental Nutrition Assistance Program $8,466
93.421 Strengthening Public Health Systems and Services Through National Partnerships to Improve and Protect the Nations Health $5,761
93.575 Child Care and Development Block Grant $5,500
93.435 Innovative State and Local Public Health Strategies to Prevent and Manage Diabetes and Heart Disease and Stroke- $4,100
93.889 National Bioterrorism Hospital Preparedness Program $1,535