Finding 240756 (2022-001)

Significant Deficiency
Requirement
N
Questioned Costs
-
Year
2022
Accepted
2023-01-17
Audit: 255318
Organization: Marin Community Clinics, Inc. (CA)
Auditor: Forvis LLP

AI Summary

  • Core Issue: Patients received sliding fee discounts that did not match the organization's policy categories.
  • Impacted Requirements: Compliance with sliding fee discount criteria outlined in federal regulations.
  • Recommended Follow-Up: Ensure staff fully understand and follow the sliding fee scale policy; implement procedures for consistent application of discounts.

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 25 patients were tested out of the total population of 228,752 encounters. The sampling methodology used is not and is not intended to be statistically valid. Three 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 ? Sliding fee discounts were given to patients that 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 ? Is not a repeat finding. Recommendation ? We recommend management continue to 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

MCC will take the following action to halt, identify and correct these inaccuracies: Team Training ? MCC will conduct trainings for all Clinic Managers, Front Office staff, Enrolment Counselor Staff, all Center staff. ? The topics at these trainings covered: ? The overall philosophy and purpose of collecting accurate data ? The importance of collecting all necessary forms and documents from patients in order to insert their financial status into MCC sliding fee scale. ? Definition of income; how to accurately calculate income ? Definition of family size / household ? The call center role in scheduling the patient appointment and how to set the document expectations ? The importance of collecting all necessary forms and documents from patients in order to insert their financial status into MCC sliding fee scale. ? How to enter accurate information into all the applicable forms in the EHR Call Center Scripting and Training MCC recognizes that the process of documentation and effective data management starts with our call center staff. MCC will implement a more prescribed and descriptive approach as to how we set these expectations with our patients. Our call center will be educating our patients and explaining the importance of bringing in income verification for our sliding fee scale. The new script will address the idea that all patients are eligible for the sliding fee discounts, not just uninsured patients. Meaning, if insured patients provide proof of income they may be eligible for a discount on their copay, coinsurance, and/or deductible. The script will also address the patient's right to decline the financial fee assessment. It will further states that refusal to provide proof of income or financial information will result in the patient not being eligible for any discounts. Internal Audits: Internal audit will be conducted on a monthly basis and discussed with clinic operation teams. Timeline- the training will start in January 2023 and will continue quarterly and every time new staff on boards throughout 2023. Responsible- There are multiple team members that are actively responsible for documentation and preservation of these documents in the correct patient charts: Clinic Manager, Front Office Supervisors, Director of Patient Services. Ultimately, MCC views this as a measure that the Chief Executive Officer, Chief Financial Officer, Chief Health Services Officer and Chief Compliance Officer all hold responsibility to ensure this policy is adhered to closely.

Categories

Special Tests & Provisions

Other Findings in this Audit

  • 240757 2022-001
    Significant Deficiency
  • 240758 2022-001
    Significant Deficiency
  • 817198 2022-001
    Significant Deficiency
  • 817199 2022-001
    Significant Deficiency
  • 817200 2022-001
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
93.224 Covid-19 - Health Center Program $7.68M
93.527 Affordable Care Act (aca) Grants for New and Expanded Services Under the Health Center Program $2.23M
93.224 Consolidated Health Centers (community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) $709,967
93.217 Family Planning_services $322,907
10.569 Emergency Food Assistance Program (food Commodities) $192,389
93.917 Hiv Care Formula Grants $115,515
93.323 Covid-19 - Epidemiology and Laboratory Capacity for Infectious Diseases (elc) $69,101
93.461 Covid-19 Testing for the Uninsured $53,037
21.019 Covid-19 - Coronavirus Relief Fund $36,293
93.958 Block Grants for Community Mental Health Services $28,595
93.889 Covid-19 - National Bioterrorism Hospital Preparedness Program $22,000