Finding 392581 (2023-003)

Finding 2023-003 Eligibility – Noncompliance and Significant Deficiency in Internal Control Over Compliance Identification of the federal program ALN 93.210 Tribal Self Governance Program - IHS Compact/Funding Agreements. Award No. 58G950015-22. Year 2023, 2022 and 2021 (COVID- 19). Criteria or specific requirement In accordance with the IHS funding agreement requirements, as well as Uniform Guidance compliance requirements, the Association is required to maintain documentation of eligibility for the patients receiving medical assistance under the IHS program. Condition The Organization was unable to provide proper documentation regarding eligibility of some of the patients for which their accounts were adjusted to the IHS compact. Cause The finance department experienced heavy turnover during 2023 that resulted in several positions being vacant for most of the year. These staffing shortages resulted in a lack of time for sufficient review. Effect or potential effect Individuals may receive services funded by the IHS program who are ineligible to receive these benefits. Questioned Costs Unknown Context We tested 40 patients who were designated as IHS beneficiaries. For 2 of these patients, documentation proving eligibility was not on file. Identification as a repeat finding None. Recommendation For all patients receiving services, verification of eligibility should be documented and kept on file electronically. If eligibility documentation is not provided, the hospital needs to attempt to collect on the outstanding balance, rather than charging the IHS Compact. It was noted that the thirdparty billing service relies on Demographic Patient Information determined by BBAHC without looking at actual proof of eligibility. We recommend the Organization require its billing service to confirm documentation on file prior to IHS adjustments and notify BBAHC if no documentation is retained. Views of Responsible Official and Planned Corrective Action Management agrees with this finding. Management has reinforced the policy requiring documentation of beneficiary status and the Patient Access Manager has developed a registration performance improvement plan.