Finding 34391 (2022-001)

Significant Deficiency
Requirement
N
Questioned Costs
-
Year
2022
Accepted
2022-12-08
Audit: 32707
Organization: Great Lakes Bay Health Centers (MI)
Auditor: Yeo & Yeo PC

AI Summary

  • Core Issue: Health centers are not consistently obtaining and approving sliding fee applications, leading to incorrect discounts for eligible patients.
  • Impacted Requirements: Compliance with AL # 93.224 and 93.527, which mandate proper documentation for sliding fee adjustments based on patient ability to pay.
  • Recommended Follow-Up: Ensure all sliding fee applications are completed and approved before billing; consider regular sampling to verify compliance throughout the year.

Finding Text

2022-001 ? Significantly Deficiency and Noncompliance ? Special Tests ? Sliding Fee Program information: AL # 93.224 and 93.527, Health Center Program Cluster, Department of Health and Human Services. Criteria: Health centers must obtain sliding fee applications so that amounts owed for health center services by eligible patients are adjusted (discounted) based on the patient?s ability to pay. Condition: We tested 40 sliding fee encounters and noted that 2 of 40 sliding fee encounters tested had did not have sliding fee applications and 3 out of 40 patients were discounted the wrong amount. Questioned Costs: None Cause and Effect: The Organization failed to verify sliding fee applications were obtained and properly approved for all patients receiving discounts and incorrectly applied sliding fee discounts to charges. Recommendation: We recommend that sliding fee applications be completed and properly approved for each sliding fee patient. Procedures should be implemented to verify applications are completed before the encounter is billed. In addition, the Organization could consider doing sampling throughout the year to verify sliding fee applications are obtained, completed, and agree to the discount applied. Views of Responsible Officials: Management agrees with the finding. Corrective Action Plan: See attached correct plan.

Corrective Action Plan

Federal Award Findings Finding number 2022-001 Significant Deficiency and Noncompliance ? Special Tests ? Sliding Fee We concur with this finding. We acknowledge that there were sliding fee discounts given without the appropriate/complete documentation being filed in the patients? chart. We have had a practice of performing internal sliding fee audits by clinical site and sharing the results with our Risk / Corporate Compliance committee and Site Managers. During COVID, some of this auditing practice fell away. Additionally, the increased usage of telehealth posed challenges in collection of patients documents, including the sliding fee and presumptive sliding fee applications. The other issue that has caused complications in this workflow is the turnover of several employee positions. There existed a Front Desk Trainer position who was integral in the training of our front desk staff responsible for the completion of the sliding fee applications. The incumbent left the position and was not replaced. This has left the role accountable for the training and implementation of such protocols unfilled. A workgroup was established of key individuals including end users to process improve this issue and other?s experienced by the front desk/revenue cycle workflow. The group concluded that the soon-to-onboard Director of Patient Support Services will be the role to oversee the entire front desk workflow with regard to billing and sliding fee. The role was filled in late November. Action Completion 1. Review and edit the sliding fee application for patient literacy and to improve the clarity of instructions for patients and employees. DONE 2. Continue internal audits but increase frequency to every quarter. (beginning January 2023) 3/31/2023 3. Establish cross functional team to analyze front desk workflow and set accountability for the administration of our sliding fee application. DONE 4. Hire Director of Patient Support Services DONE 5. Develop streamlined audit reporting tool. DONE 6. Continue to report out Sliding Fee Audit results quarterly. 3/31/2023 7. Develop an exception report tool to identify sliding fee patients with no slide application on file. 3/31/2023 Responsible Staff/Contact: Amy Evans, CMA, Chief Financial Officer; Email: aevans@glbhealth.org; Voice: 989-759-6438

Categories

Special Tests & Provisions

Other Findings in this Audit

  • 34392 2022-001
    Significant Deficiency
  • 34393 2022-001
    Significant Deficiency
  • 610833 2022-001
    Significant Deficiency
  • 610834 2022-001
    Significant Deficiency
  • 610835 2022-001
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
92.527 Affordable Care Act (aca) Grants for New and Expanded Services Under the Health Center Program $6.02M
93.498 Provider Relief Fund $3.75M
93.224 Consolidated Health Centers (community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) $1.18M
10.557 Special Supplemental Nutrition Program for Women, Infants, and Children $593,063
21.019 Coronavirus Relief Fund $461,037
93.940 Hiv Prevention Activities_health Department Based $126,516
93.092 Affordable Care Act (aca) Personal Responsibility Education Program $112,990
93.461 Covid-19 Testing for the Uninsured $81,413
32.006 Covid-19 Telehealth Program $51,075
93.917 Hiv Care Formula Grants $21,592