Finding 369760 (2023-001)

Significant Deficiency Repeat Finding
Requirement
N
Questioned Costs
-
Year
2023
Accepted
2024-02-20
Audit: 291274
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.
  • Impacted Requirements: Compliance with sliding fee discount criteria as outlined in federal regulations.
  • Recommended Follow-Up: Enhance training on the new system and ensure adherence to the sliding fee scale policy to prevent future discrepancies.

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 40 patients were tested out of the total population of 207,818 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 balances of the patients were inconsistent with the Organization’s sliding fee discount policy. Cause – The Organization did not comply with their sliding fee policy. The electronic health record system that was implemented during the year had some configuration issues that resulted in sliding fee discounts not properly being applied. Identification as a repeat finding, if applicable – Yes. Finding 2022-001. Recommendation – We recommend management continue to train personnel in the new practice management system and 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: Dental CDT Codes Correction: Due to new electronic health record implementation few dental CDT codes were not properly configured to attach the discount. The issue has been quickly identified by the billing team and corrected in March 2023, however some patients had an inaccurate balance although they had the correct documentation and the correct discount assigned and charged to them. The patients are not additionally charge as the billing team is adjusting the remaining balance. The billing team will run a report and identify all affected patients. Timeline - a report for the CDT codes will be run by end of Q4-FY24. Completion: All balances will be adjusted by end of Q4-FY24. Team Training • MCC will continue to conduct trainings for all Clinic Managers, Front Office staff and Call Center staff. • The topics at these trainings covered: o The overall philosophy and purpose of collecting accurate data o The importance of collecting all necessary forms and documents from patients in order to insert their financial status into MCC’s sliding fee scale. o Definition of income; how to accurately calculate income. o Definition of family size / household. o The call center role in scheduling the patient appointments and how to set the document expectations. o The importance of collecting all necessary forms and documents from patients in order to insert their financial status into MCC sliding fee scale. o How to enter accurate information into all the applicable forms in the EHR. o Operational workflow. Team Training Timeline - the training will continue of a quarterly basis throughout 2024. Completion: We attest that Fourth Quarter of calendar year 2023 was completed. Internal Audits: Timeline: Internal audit will be conducted on a monthly basis and discussed with clinic operation teams. Completion: We attest that monthly audits are implemented and discussed with clinic operations. 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. Contact person for Corrective Action Plan listed above: Isabela Mihai, CHC, CHPC, Chief Compliance Officer Tel: 415-755-2509 Email: imihai@marinclinic.org

Categories

Special Tests & Provisions

Other Findings in this Audit

  • 369761 2023-001
    Significant Deficiency Repeat
  • 369762 2023-001
    Significant Deficiency Repeat
  • 369763 2023-001
    Significant Deficiency Repeat
  • 946202 2023-001
    Significant Deficiency Repeat
  • 946203 2023-001
    Significant Deficiency Repeat
  • 946204 2023-001
    Significant Deficiency Repeat
  • 946205 2023-001
    Significant Deficiency Repeat

Programs in Audit

ALN Program Name Expenditures
93.498 Provider Relief Fund $1.59M
21.027 Coronavirus State and Local Fiscal Recovery Funds $692,500
93.526 Affordable Care Act (aca) Grants for Capital Development in Health Centers $308,666
93.323 Epidemiology and Laboratory Capacity for Infectious Diseases (elc) $203,588
10.569 Emergency Food Assistance Program (food Commodities) $202,229
93.917 Hiv Care Formula Grants $96,850
93.217 Family Planning_services $67,896
93.224 Consolidated Health Centers (community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) $65,500
93.527 Affordable Care Act (aca) Grants for New and Expanded Services Under the Health Center Program $63,208
21.019 Coronavirus Relief Fund $22,608
97.024 Emergency Food and Shelter National Board Program $2,524