Finding 370294 (2023-001)

Significant Deficiency
Requirement
J
Questioned Costs
-
Year
2023
Accepted
2024-02-23

AI Summary

  • Core Issue: The Organization failed to consistently apply the sliding fee schedule for patient discounts, impacting compliance with federal requirements.
  • Impacted Requirements: Compliance with Title 42 regulations regarding fee schedules and patient eligibility determination.
  • Recommended Follow-Up: Enhance billing processes and claims analysis to ensure proper application of discounts and improve program income.

Finding Text

Finding 2023-001 – Sliding Fee Discount Program Federal Agency: U.S. Department of Health and Human Services Federal Program: Consolidated Health Centers Cluster AL Number: 93.224 / 93.527 Award Number: H80CS28351 Award Year: 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria: Per Title 42 Chapter 1 Subchapter D Section 51c303(f)(g), “Health centers must have a schedule of fees or payments for the provision of their health services consistent with locally prevailing rates or charges designed to cover their reasonable costs of operation and a corresponding schedule of discounts adjusted on the basis of the patient’s ability to pay” and “Make every reasonable effort, including the establishment of systems for eligibility determination, billing, and collection.” Condition: During our special testing related to the Organization’s sliding scale, it was determined that the Organization did not consistently follow the sliding fee schedule in place. This occurred in one of the twenty sampled patients. Cause: Review procedures were not followed within the Organization which caused issues in consistent application of the sliding schedule in accordance with the Organization’s policy. Effect: Potential that a patient would not receive the appropriate sliding fee discount. Recommendation: We recommend the continued improvement of the process of billing encounters and analyzing claims to maximize the Organization’s program income and maintain compliance with the Sliding Fee Discount Program. Management’s Response: See Corrective Action Plan.

Corrective Action Plan

Finding Number: 2023-001 Anticipated Completion Date: May 2024 Responsible Contact Person: David Tatro, CEO Planned Corrective Action: The Organization provided 2,682 self-pay encounters to be audited for the year ended May 31, 2023. Out of the 2,682 self-pay encounters, 20 were identified for further review. Two self-pay accounts were identified with issues which resulted in this finding. The first issue was attributed to a patient inaccurately placed on a slide level, and the other patient account did not have an updated sliding fee scale application completed on file. This issue has been resolved as of November 2023 by reviewing all sliding fee scale applications for accuracy. The Organization will continue to monitor the sliding fee scale amounts applied to ensure ongoing compliance with the requirements. The Organization will review five sliding fee scale applications each week to ensure eligibility determination, billing and collection follows the Sliding Fee Discount Program. This will go through May 2024 with a reassessment at that point, based on the results of the internal review.

Categories

Eligibility Significant Deficiency Program Income Internal Control / Segregation of Duties

Other Findings in this Audit

  • 370295 2023-001
    Significant Deficiency
  • 370296 2023-001
    Significant Deficiency
  • 946736 2023-001
    Significant Deficiency
  • 946737 2023-001
    Significant Deficiency
  • 946738 2023-001
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
93.224 Consolidated Health Centers (community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) $816,650
93.526 Affordable Care Act (aca) Grants for Capital Development in Health Centers $493,920
93.498 Provider Relief Fund $315,941
93.527 Affordable Care Act (aca) Grants for New and Expanded Services Under the Health Center Program $126,418