Finding 409863 (2022-001)

Significant Deficiency Repeat Finding
Requirement
N
Questioned Costs
-
Year
2022
Accepted
2022-11-09
Audit: 311953
Organization: Health Services, Inc. (AL)

AI Summary

  • Core Issue: The sliding fee discount system is not being applied correctly, leading to incorrect patient charges.
  • Impacted Requirements: Compliance with 42 CFR Section 51c.303(d) and (f) regarding fee schedules and documentation is lacking.
  • Recommended Follow-Up: Strengthen policies and procedures for the sliding fee scale to ensure accurate application and documentation.

Finding Text

Finding 2022-001 ? Special Tests and Provisions ? Sliding Fee (repeat finding)Information on the federal program: U.S. Department of Health and Human Services CFDA No.93.224 and 93.527 Health Center Program ClusterCriteria: 42 CFR Section 51c.303(d) defines required project elements to include developing a soundcontrol system to ensure compliance with the regulations and terms and conditions of the grant. 42CFR Section 51c.303(f) establishes the requirement to have a schedule of fees or payments for theprovision of its services designed to cover its reasonable costs of operation and a correspondingschedule of discounts adjusted on the basis of the patient's ability to pay. Such schedule of discountsshall provide for a full discount to individuals and families with annual incomes at or below those setforth in the most recent CSA Poverty Income Guidelines and for no discount to individuals and familieswith annual incomes greater than twice those set forth in such Guidelines, except that nominal feesfor services may be collected from individuals with annual incomes at or below such levels whereimposition of such fees is consistent with project goals.Condition: We tested the controls over the application of the sliding scale fee discount for 40 patientvisits during the year. Out of the 40 tested, we noted 6 patients with one or more exceptions. Wenoted 5 instances in which the sliding fee discount was not properly applied and 5 instances in whichthe income documentation did not agree to the income amount used to determine the discount. Inaddition, we noted that documentation of review of the patient files was not properly documented.Cause: Eligibility documentation obtained by HSI for each patient is accumulated using an intakeform and income verification source documents. Per the Organization, the control system over thesliding fee program includes periodic review of patient files for accuracy and completeness. Thesefile reviews were not properly documented and therefore could not be verified as performed. For theexceptions noted by testing compliance, the income source documentation on file did not agree tothe income amount in the system used to determine the discount or the eligibility documentation wasnot properly evaluated and entered into the system. Therefore, the information used to apply thesliding fee discount was incorrect.Effect: Sliding fee discounts were not appropriately applied and patients were charged the incorrectamounts.Recommendation: We recommend the Organization strengthen its policies and proceduressurrounding the sliding fee scale to ensure compliance with the special tests and provisionrequirements.Views of Responsible Officials and Planned Corrective Action: See Management?s View andCorrective Action Plan included at the end of the report.

Corrective Action Plan

Finding 2022-001 ? Special Tests and ProvisionsThe auditee acknowledges the findings of the auditors. It has been noted that two patients were billedat discounts above eligibility levels and one patient was billed at a discount below the eligible amount.Review of the samples noted revealed that one of the 3 individuals included in the finding occurredas a result of staff inputting the incorrect salary information into the system for those patients and/ornot selecting the proper frequency for patient income, i.e., monthly, weekly, biweekly, annually, etc.These are simple human errors that occur when staff are inundated with tasks during registrationmissing detailed steps as they enter the patient?s income.Another instance of the noted error existed as a result of the staff failing to include the income for allindividuals in the household income calculation which provided a greater than applicable discount.The final error occurred as a result of failure to follow up and adjust patient accounts for those patientswho present and apply for the sliding fee. This patient applied for the sliding fee discount at the timeof the visit, but because he did not have the income verification, he was listed as self-pay and givena 30 day notice to provide the information. The patient paid toward the balance and once he providedinformation it was determined that his payment on the day of the visit exceeded the required paymentper the sliding fee. Supervisors failed to adjust the account and provide the patient with a refund, asa result patient?s account did not reflect the proper discount.Plan of Action:Management reviewed the findings and began to rationalize the reasons that these findings occurredand measures that will help to reduce these errors. The course of action to be taken includes thefollowing to be implemented immediately:? Reduction of Turnover in PAR. A contributing factor to the errors with sliding fees is turnoverin the department. There is a considerably high percentage of turnover average of 6%. Errorsare existing due to the turnover of staff, and the constant training.? Strengthened procedures for Supervisors of employees registering patients are nowcompleting audits of patients? charts to review the sliding fee scale and the attacheddocumentation. The audits are conducted on the patient account as they present for service.Because of the nature of the Sliding Fee Program, the documentation required toparticipated, and the setup of our Patient Management System (Athena), these areperformance audits and are based on how accurate each employee enters information intothe system.? Training to reiterate avoiding common mistakes while registering patients and workingwith patient information.? Also, as recommended, we have scheduled a date to renew the annual sliding fee scaleand notify patients. As an added measure, we will also commit to documenting the effectivedates for any leniency in the corresponding Board minutes.

Categories

Special Tests & Provisions Eligibility

Other Findings in this Audit

  • 409864 2022-001
    Significant Deficiency Repeat
  • 409865 2022-001
    Significant Deficiency Repeat
  • 409866 2022-001
    Significant Deficiency Repeat
  • 409867 2022-001
    Significant Deficiency Repeat
  • 409868 2022-001
    Significant Deficiency Repeat
  • 986305 2022-001
    Significant Deficiency Repeat
  • 986306 2022-001
    Significant Deficiency Repeat
  • 986307 2022-001
    Significant Deficiency Repeat
  • 986308 2022-001
    Significant Deficiency Repeat
  • 986309 2022-001
    Significant Deficiency Repeat
  • 986310 2022-001
    Significant Deficiency Repeat

Programs in Audit

ALN Program Name Expenditures
93.498 Provider Relief Fund $702,687
93.224 Consolidated Health Centers (community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) $282,866
10.557 Special Supplemental Nutrition Program for Women, Infants, and Children $218,729
93.527 Affordable Care Act (aca) Grants for New and Expanded Services Under the Health Center Program $185,806
93.738 Pphf: Racial and Ethnic Approaches to Community Health Program Financed Solely by Public Prevention and Health Funds $30,600
14.218 Community Development Block Grants/entitlement Grants $9,015