Finding 4954 (2021-002)

Significant Deficiency Repeat Finding
Requirement
N
Questioned Costs
-
Year
2021
Accepted
2023-12-18

AI Summary

  • Core Issue: Alluvion Health failed to consistently apply its sliding fee scale policy, leading to improper documentation and incorrect discounts for some patients.
  • Impacted Requirements: The Health Center Program Compliance Manual mandates proper procedures for assessing patient income and family size for sliding fee discounts.
  • Recommended Follow-Up: Alluvion Health should review and update its policies and provide ongoing training to staff involved in sliding fee scale assessments.

Finding Text

#2021-002 – Misapplication of the Sliding Fee Scale CFDA Number: 93.224 and 93.527 Health Centers Cluster (Repeat Finding) Condition: Alluvion Health did not properly follow its sliding fee scale policy and procedures for patients that applied for a sliding fee discount and did not properly maintain documentation to support qualification and the sliding fee discount received. Criteria: The Health Center Program Compliance Manual requires a health center to have operating procedures for assessing and re-assessing all patients for income and family size consistent with approved sliding fee discount program policies. Effect: No material noncompliance or questioned costs were noted in the period under audit. Context: Our testing detected 4 out of 60 patients selected for testing either did not have proper documentation to support their qualification of the sliding fee discount received or received an incorrect discount. Cause: Inconsistent application of the policies and procedures approved by Alluvion Health. Recommendation: We recommend Alluvion Health review its current policies and procedures and continue to provide training to all staff members handling the sliding fee scale assessments to ensure assessments are performed in accordance with policy. Management Response to Findings: See corrective action plan.

Corrective Action Plan

Finding # 2021-002 – Misapplication of the Sliding Fee Scale Response: Beginning in July of 2020 the Organization revised sliding fee scale audit criteria and procedures. The audit currently consists of 50 patients being audited against 16 criteria, and continues to be reported to the Board of Directors Quality Committee and the BOD on a monthly basis. The average monthly percentage performances in what will be FY22 and FY23, are 68% and 79% respectively, which is a positive trend over the FY21 audit figure of 67% (4/60). Considering that the bulk of the slide procedure is performed by entry level patient registration staff who have bore the brunt of patient challenges due to the COVID-19 pandemic and who tend to take advantage of job mobility in a strong jobs market, turnover and training have impacted compliance. Upon review of the policy and procedure in 2023, it was determined that the BOD will be engaged to discuss lengthening the proof of income duration when providing paystubs, from 3 months to 12 months, which will standardize all forms of proof of income to be valid for 12 months. The intent is to simplify the process in terms of the ability of registration staff to understand and execute procedures in the midst of a busy patient-facing clinic setting. Upon revision to the policy, all policies, procedures, and training materials will be updated, and all current/new staff will be trained. Responsible Party(s) Mark Groeller, Compliance Director Lisa DeMallie, Associate Vice President of Patient Experience Estimated Completion Date 12/31/23

Categories

No categories assigned yet.

Other Findings in this Audit

  • 4955 2021-003
    Significant Deficiency Repeat
  • 4956 2021-002
    Significant Deficiency Repeat
  • 4957 2021-003
    Significant Deficiency Repeat
  • 581396 2021-002
    Significant Deficiency Repeat
  • 581397 2021-003
    Significant Deficiency Repeat
  • 581398 2021-002
    Significant Deficiency Repeat
  • 581399 2021-003
    Significant Deficiency Repeat

Programs in Audit

ALN Program Name Expenditures
93.224 Consolidated Health Centers (community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) $2.10M
93.527 Affordable Care Act (aca) Grants for New and Expanded Services Under the Health Center Program $53,114