Finding Text
Criteria: The HRSA COVID-19 Uninsured Program, ALN 93.461, allows for reimbursement for COVID-19 testing and testing-related items, as well as for COVID-19 treatment for individuals who were either uninsured or under-insured at the time services were rendered. The guidance for this program provides specific diagnostic coding and treatments that are allowable to be reimbursed under this program.
Condition: HRSA’s website indicated that the Company had received $1,222,565 of funds under this program for the period from July 1, 2019 through June 30, 2022. However, management was initially unaware that they had received funding from this program and could not provide an underlying detail of the patient visits that were reimbursed under this program. Management worked with both of the Company’s third-party billing providers, and after several months, provided a detail from July 1, 2019 through June 30, 2022 that totaled $905,771, which resulted in an initial, unreconciled difference of $316,794. Further, during testing procedures of the billing detail provided, which consisted of a sample of 120 items, we noted 47 instances where the patient visits did not appear to meet the allowable activities under the program. As a result, we identified total factual misstatements of $14,578, which projected to additional misstatements of $411,291.
Effect: Due to the initial detail variance and the projected misstatements from testing, an audit adjustment of $742,663 was recorded, which reduced net patient service revenue and recorded a liability back to HRSA.
Cause: The staff of the Company oversees and administers physician services within the emergency departments of nine area hospitals. The hospitals' personnel are assigned the task of patient registration, ensuring the precise entry of patients' insurance data into the medical records system. Subsequently, an error occurred as some patients were inaccurately marked as eligible for the HRSA uninsured program by the hospital staff. Consequently, this led to unintended discrepancies in the submission of claim reimbursements by the Company's third-party billing vendors to the program, some of which were not in accordance with the related compliance regulations.
Recommendation: We recommend that management implement procedures and controls to ensure that they are fully aware of all federal funds that are being received, and that the Company’s policies and corresponding activities are in accordance with the related federal compliance guidelines, including discussions with the local area hospitals.
Repeat finding: No
Views of responsible officials and planned corrective actions: See attached letter.
Reportable questioned costs: None
Views of responsible officials and planned corrective actions: See attached letter.