Finding Number: 2023-001, 2022-001, 2021-001:
Material Weakness and Material Noncompliance - Sliding Fee
Recommendation: We recommend that sliding fee applications be completed for each sliding fee patient. Procedures should be implemented to verify applications are completed before the encounter is billed. Sliding fee discounts per policy should be agreed in the billing system to ensure the proper discounts are entered and updated. In addition, the Center could consider increasing its internal sampling throughout the year to verify sliding fee applications are obtained, completed, and agree to the discount applied.
Action Taken: CHASS management concurs with the audit finding and will put the following corrective action plan in place to mitigate this finding in the future:
During Sliding Fee Testing it was found that the actual charge to patient (after slidingfee applied) did not match the actual discount that patient should have had. We have reviewed all process on how EPIC loads up charges (table with applied slidingfee tiers) and found that no one had a master list of the charges, when Billing requests a CPT to be added they just go to accounting and gets added as well as when they request changes on charges for CPT code. There is not one set of approved CPT charges/discount creating discrepancies in patients accounts. In
response to these audit findings, CHASS has developed and implemented a comprehensive series of improvements.
First, implementation of key improvements involves the implementation of a one person only authorized to request changes on table of charges to EPIC.
Second, implementation of a verification process for every patient receiving a sliding fee discount. To achieve this, the Center's Customer Service team now generates personalized labels for each eligible patient and cross-checks their entries by the end of each day. This process ensures each item is diligently reviewed to ensure if any errors are made within this process they are rectified immediately via a Supervisor/Team Leader. Through this process the Supervisor/Team Leader now conducts a second review of the labels to ensure
accuracy of the Center's labeling system for each patient utilizing the sliding scale discount program. This review also includes the actual charges on EPIC and Discount being verified with CPI Tables.
Third implementation, the Center's Billing Department is now responsible for performing regular weekly audits. During these audits, the Billing Department will now randomly select five claims with sliding fee discounts and examine the applied fees and the corresponding discounts applied to the patient's account (using the approved CPT Table).
Through these improvements CHASS aims to ensure that the Sliding Fee
Discount Policy is used accurately and appropriately. These methods have been incorporated into the Center's Sliding Fee Discount Policy to guarantee their utilization and accuracy, and to further strengthen the Center's initiatives in providing access to needed health care services.
Responsible Parties: Angela Salgado, Chief Operating Officer