Finding 35390 (2022-003)

Significant Deficiency
Requirement
N
Questioned Costs
-
Year
2022
Accepted
2023-03-23

AI Summary

  • Core Issue: Two patients received larger sliding fee discounts than they were eligible for based on their income and family size.
  • Impacted Requirements: Compliance with federal regulations requiring accurate sliding fee discount schedules based on patients' ability to pay.
  • Recommended Follow-Up: Increase self-reviews of patient encounters and provide additional training for front desk staff on collecting and verifying patient information.

Finding Text

Finding 2022-003 ? Special Provisions Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Health Centers Cluster Assistance Listing Number: 93.224 and 93.527 Federal Award Identification Number: H80CS02457-18; H80CS02457-19 Award Periods: February 1, 2021 ? January 31, 2022; February 1, 2022 ? January 31, 2023 Type of Finding: Compliance and significant deficiency in internal control over compliance Criteria: Health centers must prepare and apply a sliding fee discount schedule so that the amounts owed for health center services by eligible patients are adjusted (discounted) based on the patient?s ability to pay. (42 USC 254(k)(3)(E), (F), and (G); 42 CFR sections 51c.303(e), (f), and (g); and 42 CFR sections 56.303(e), (f), and (g)). Condition: The organization had assessed two patients with a larger sliding fee discount than for which they were eligible based on their family size and income documentation. Questioned Costs: None. Context: Two (2) of Forty (40) transactions selected for testing. Cause: One patient did not have a current sliding fee assessment of family size and income and one patient was assigned a higher discount under an alternative sliding fee scale that allowed for a sliding fee discount up to 250% of the federal poverty guidelines, but which was ultimately rescinded and replaced with a sliding fee scale that does not exceed 200% of the federal poverty guidelines. Effect: Applicants assessed are not charged according to the Organization's sliding fee scale and their ability to pay. Repeat Finding: No. Recommendation: Management should consider increasing the frequency of its self-reviews of patient encounters or expanding its sample sizes in addition to providing additional training for front desk staff regarding the collection and verification of patient information for each patient. Views of Responsible Officials: There is no disagreement with the audit finding.

Corrective Action Plan

2022-003 Health Centers Cluster ? Assistance Listing No. 93.224 and 93.527 Recommendation: Management should consider increasing the frequency of its self-reviews of patient encounters or expanding its sample sizes in addition to providing additional training for front desk staff regarding the collection and verification of patient information for each patient. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: 1) Expired sliding fee application Design, implement, and review a monthly report to ensure that the appropriate employees are making the Financial Assistance (FA) and Sliding Fee Discount Program adjustments. Every 2 months ? internal audits of FA and Self Pay patient accounts will be completed and documented. Additional training will be completed and documented for all Revenue Cycle Team members. We will review Discount Program along with Financial Assistance policies and procedures and discuss our financial policy related to ? Sliding Fee Scale. 2) Incorrectly assigned discount due to brief variation in sliding fee tables to expand the number of patients eligible to receive discounts. Heartland?s policies and procedures clearly reflect that the sliding fee scale discount program will only be extended to eligible patients up to 200% of the federal poverty guidelines. The Revenue Cycle Manager and CFO will ensure on a every 2-month basis that no slides will be given to ineligible patients based on income and family size. This monthly review will be documented, approved, and filed by fiscal year. Name(s) of the contact person(s) responsible for corrective action: Michael Cohlman, CFO and Katie Saucedo, Revenue Cycle Manager Planned completion date for corrective action plan: 4/1/23

Categories

Significant Deficiency Internal Control / Segregation of Duties Special Tests & Provisions

Other Findings in this Audit

  • 35389 2022-002
    Significant Deficiency
  • 35391 2022-002
    Significant Deficiency
  • 35392 2022-003
    Significant Deficiency
  • 35393 2022-002
    Significant Deficiency
  • 35394 2022-003
    Significant Deficiency
  • 35408 2022-002
    Significant Deficiency
  • 611831 2022-002
    Significant Deficiency
  • 611832 2022-003
    Significant Deficiency
  • 611833 2022-002
    Significant Deficiency
  • 611834 2022-003
    Significant Deficiency
  • 611835 2022-002
    Significant Deficiency
  • 611836 2022-003
    Significant Deficiency
  • 611850 2022-002
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
93.527 Affordable Care Act (aca) Grants for New and Expanded Services Under the Health Center Program $2.13M
93.224 Consolidated Health Centers (community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) $1.86M
93.526 Affordable Care Act (aca) Grants for Capital Development in Health Centers $671,100
93.332 Cooperative Agreement to Support Navigators in Federally-Facilitated and State Partnership Marketplaces $66,934