Finding 400870 (2023-001)

Significant Deficiency Repeat Finding
Requirement
N
Questioned Costs
-
Year
2023
Accepted
2024-06-14
Audit: 308896
Auditor: Forvis LLP

AI Summary

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

Finding Text

Health Center Program Cluster Assistance Listing Numbers 93.224 and 93.527 U.S. Department of Health and Human Services 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 Health Center’s policy. Questioned costs – None Context – A sample of 40 encounters were tested out of the total population of 150,002 encounters. The sampling methodology used is not and is not intended to be statistically valid. Three patients received a sliding fee adjustment that was inconsistent with the approved policy based on their income documentation. Effect – Sliding fee discounts were given to patients that were inconsistent with the Health Center’s sliding fee discount policy. Cause – The Health Center did not comply with their sliding fee policy. Identification as a repeat finding – Repeat finding of 2022-001. Recommendation – It is recommended that 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

Description of Finding: Sliding fee discounts were given to three of the 40 patients tested that were inconsistent with the Health Center’s sliding fee discount policy. Statement of Concurrence: Shasta Community Health Center (SCHC) management agrees with the finding related to sliding fee discounts being provided to a small number of patients inconsistent with the Health Center’s sliding fee discount policy. The finding suggests that staff miscalculated which discount these patients would qualify for based on the income documented on the sliding fee forms. This miscalculation caused incorrect sliding fee discounts to be provided. Corrective Action: Miscalculations seem to be the leading cause of the errors noted by the auditors. Ongoing training/internal audits needs to be more robust to ensure staff understand and accurately calculate which discount the patient qualifies for. Center Managers shall review the slide audits to determine which employees are making errors and provide re-training or corrective action as applicable and document/monitor for improvement. In addition, SCHC is in the process of launching a computer-based patient form completion system, which will calculate the slide fee automatically, removing much of the human element, and thereby greatly reducing the likelihood of miscalculation. We will continue to perform audits on the new process to ensure we see an improvement in our administration of the sliding fee discount program. Individual Primarily Responsible for Corrective Action: Chief Operations Officer Projected Completion Date: Center Managers will begin documenting retraining/corrective action taken based on sliding fee audit starting June 2024. SCHC is in the process of creating the electronic forms needed to launch the computer-based registration and income verification. We expect the forms to be ready to go live late Fall, early Winter.

Categories

Special Tests & Provisions

Other Findings in this Audit

  • 400871 2023-001
    Significant Deficiency Repeat
  • 400872 2023-001
    Significant Deficiency Repeat
  • 400873 2023-001
    Significant Deficiency Repeat
  • 977312 2023-001
    Significant Deficiency Repeat
  • 977313 2023-001
    Significant Deficiency Repeat
  • 977314 2023-001
    Significant Deficiency Repeat
  • 977315 2023-001
    Significant Deficiency Repeat

Programs in Audit

ALN Program Name Expenditures
93.527 Affordable Care Act (aca) Grants for New and Expanded Services Under the Health Center Program $4.47M
93.224 Covid-19: Consolidated Health Centers (community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) $1.24M
93.224 Consolidated Health Centers (community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) $981,588
93.526 Affordable Care Act (aca) Grants for Capital Development in Health Centers $273,774
93.958 Block Grants for Community Mental Health Services $263,545
93.918 Grants to Provide Outpatient Early Intervention Services with Respect to Hiv Disease $237,148
93.917 Hiv Care Formula Grants $220,470
93.788 Opioid Str $179,659
93.527 Covid-19: Affordable Care Act (aca) Grants for New and Expanded Services Under the Health Center Program $34,415
97.024 Emergency Food and Shelter National Board Program $6,349