Finding 382603 (2023-001)

Significant Deficiency Repeat Finding

Requirement

Questioned Costs

Year

2023

Accepted

2024-03-20

Audit: 296176

Organization: Aids Action Coalition of Huntsville and Subsidiary (AL)

Auditor: Forvis LLP

AI Summary

Core Issue: Patients received sliding fee discounts that did not match the organization's policy categories.
Impacted Requirements: Compliance with sliding fee discount regulations (42 USC 254(k)(3)(g); 42 CFR sections 51c.303(g) and 56.303(f)).
Recommended Follow-Up: Ensure all staff understand and follow the sliding fee scale policy; implement procedures for accurate discount application.

Finding Text

Health Center Program Cluster – CFDA Nos. 93.224 and 93.527 U.S. Department of Health and Human Services Award No. 5 H80CS33642-05-00 Program Year 2023 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 out of 16,516 encounters were tested and 4 errors were noted where patients received an incorrect sliding fee adjustment. The sampling methodology used is not and is not intended to be statistically valid. Four 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 discounts were given to patients that were inconsistent with the Organization’s sliding fee discount policy. Cause – The Organization did not comply with their sliding fee policy. Identification as a repeat finding, if applicable – Is a repeat finding of 2022-001. Recommendation – We recommend management continue to 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

Corrective Action Plan Fiscal Year Ending September 30, 2023 Management recognizes the importance of following the program requirements established by the Health Resources Administration through the Bureau of Primary Health Care in the Health Center Program Compliance Manual. Reference # 2023-001 In order to ensure the sliding fee discounts are consistently calculated and applied to patients’ accounts, Thrive changed the EMR set up to increase automation in September 2021, which reduced manual transactions and potential sliding fee errors. Thrive continues to review and have discussions of the Sliding Fee Policy and Procedures with the outsourced billing company who is aware of, understands, and following to the best of their abilities. In this year’s FY23 audit, there was an overlap of when the sliding fee discount adjustment problems occurred and when Thrive became aware of concerns in the previous FY22 audit and updated procedures to eliminate future problems. In this current FY23 audit, sliding fee discount findings showed 3 of the 4 issues were for dates of service 11/2/22; 12/12/22; and 2/1/23. These occurrences were before we ramped up our internal audit procedures to include having our billing company monitor the accuracy of slide adjustments. This is done by running a monthly report of slide adjustments and spot checking 20-30 accounts for accuracy. Comments are made on the monthly list and saved. Any concerns are investigated. To mitigate this situation even further, beginning in February 2024, the monitoring will increase to a minimum of 90 slide adjustments per month. This will be accomplished by the Medical Billing & Coding Specialist, Sara Heflin, and the Controller, Cindy Gervie, each participating along with the billing company to audit at least 30 slide adjustments per month. Other procedures currently in place to monitor sliding fee discounts include monthly audits which began September 2021. These audits are conducted by Carmen Fortson, Director of Patient Access and Natoris Harris, Patient Access Manager. They both audit 5 charts per provider and choose an additional 5 charts at random for additional testing. They review the sample for: sliding fee discounts applied, correct insurance information, documentation of proof of income, correct Federal Poverty Limit designation, and discount calculations. Any discrepancies are investigated and providers and management are educated in best practices. The monthly review also includes an internal audit of client records to identify patients that have provided the proper proof of income and qualify for the sliding fee discount but are not receiving the discount. If this situation occurs, training will be conducted by Carmen or Natoris with staff. Stephanie Harville Chief Financial Officer

Other Findings in this Audit

382604 2023-001

Significant Deficiency Repeat
382605 2023-001

Significant Deficiency Repeat
382606 2023-001

Significant Deficiency Repeat
959045 2023-001

Significant Deficiency Repeat
959046 2023-001

Significant Deficiency Repeat
959047 2023-001

Significant Deficiency Repeat
959048 2023-001

Significant Deficiency Repeat

Programs in Audit

ALN	Program Name	Expenditures
93.918	Grants to Provide Outpatient Early Intervention Services with Respect to Hiv Disease	$650,860
93.243	Substance Abuse and Mental Health Services_projects of Regional and National Significance	$500,000
93.224	Consolidated Health Centers (community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care)	$393,024
93.940	Hiv Prevention Activities_health Department Based	$286,287
93.268	Immunization Cooperative Agreements	$267,929
93.153	Coordinated Services and Access to Research for Women, Infants, Children, and Youth	$150,000
14.241	Housing Opportunities for Persons with Aids	$113,116
93.917	Hiv Care Formula Grants	$107,874
93.527	Affordable Care Act (aca) Grants for New and Expanded Services Under the Health Center Program	$100,685
93.242	Mental Health Research Grants	$93,458
16.575	Crime Victim Assistance	$74,092
14.238	Shelter Plus Care	$14,867