Finding 497398 (2024-001)

Material Weakness
Requirement
N
Questioned Costs
-
Year
2024
Accepted
2024-09-20
Audit: 320145

AI Summary

  • Core Issue: Patients did not receive the correct sliding fee discounts as per the Organization's policy.
  • Impacted Requirements: Compliance with sliding fee policy was not met, leading to incorrect discounts.
  • Recommended Follow-Up: Management should ensure staff are trained on the sliding fee policy and implement automated systems to reduce errors.

Finding Text

U.S. Department of Health and Human Services Federal Assistance Listing Number 93.224 and 93.527 Health Center Program Cluster Criteria or Specific Requirement: Special Tests and Provisions: Sliding Fee Discounts Condition: Patients did not receive the proper sliding fee adjustments under the Organization’s policy. Questioned Costs: None Context: A sample of 25 patients were tested out of a total population of 3,222 encounters. Two patients did not receive the proper sliding fee adjustments. The sampling methodology used is not and not intended to be statistically valid. Effect: Incorrect sliding fee discounts were given to patients. Cause: The Organization did not comply with its sliding fee policy. Identification as a Repeat Finding, if Applicable: Not a repeat finding. Recommendation: We recommend management continues to ensure all personnel understand the sliding fees 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. Views of Responsible Officials and Planned Corrective Actions: The Organization concurs with the findings. CABUN will open an item with Aprima requesting a modification to the Practice Management system to make an automatic classification of the slide category instead of a manual classification as is currently required. Front Office, Billing and Collections staff will be reeducated on the entire process of sliding fee; from application to ensuring adjustments are made correctly. A new version of the slide application will be considered to simplify the process. CABUN will go back to a 100% review of all sliding fee patients, with a second audit in place to spot checking behind the Billing department. 1. Patient applications will be updated using the new version. 2. On the CHC tab where the slide is mentioned, the requested modification once made will become an automatic entry instead of a manual entry to prevent errors. 3. When the insurance is created, the slide category will match not only the CHC tab, but the application as well. 4. Billing will make any corrections to the slide applications and categories, and when errors are made directly contacting the person making the error for reeducation. Management and all personnel involved will review and determine the appropriate sliding fee discount in order to be in compliance with Uniform Guidance. All patients will be offered an application to participate in the sliding fee discount. Information will be entered into the syste as declined or appropriate to arrive at the sliding fee category. The application will then come to Hampton where a billing clerk will review the application for accuracy. The CHC and Insurance tab will reflect the correct sliding fee category. Corrections to the patient account will be made if there are any inaccuracies found. Education will be provided to those making the error and corrective action taken if continued omissions. In the Organizations PMS, the slide is setup as an insurance, if no other insurance is primary the adjustment is automatically made. The PMS has been checked for accuracy of slide categories, adjustment codes and insurance types.

Corrective Action Plan

Contact Name: Judy Southall, CFO Contact Phone Number: 870-798-4064 Audit Period Ending: March 31, 2024 Audit Firm: Forvis Mazars, LLP Federal Program: Health Center Cluster Program, Assistance Listing Number: 93.224, 93.527 Federal Agency: U.S. Department of Health and Human Services Reference Number 2024-001: Finding – Statement of Condition – Patients did not receive the proper sliding fee adjustments under the Organization’s policy. Views of Responsible Officials and Planned Corrective Action - The Organization concurs with the findings. CABUN will open an item with Aprima requesting a modification to the Practice Management system to make an automatic classification of the slide category instead of a manual classification as is currently required. Front Office, Billing and Collections staff will be re-educated on the entire process of sliding fee; from application to ensuring adjustments are made correctly. A new version of the slide application will be considered to simplify the process. CABUN will go back to a 100% review of all sliding fee patients, with a second audit in place to spot checking behind the Billing department. 1. Patient applications will be updated using the new version. 2. On the CHC tab where the slide is mentioned, the requested modification once made will become an automatic entry instead of a manual entry to prevent errors. 3. When the insurance is created, the slide category will match not only the CHC tab, but the application as well. 4. Billing will make any corrections to the slide applications and categories, and when errors are made directly contacting the person making the error for reeducation. Management and all personnel involved will review and determine the appropriate sliding fee discount in order to be in compliance with Uniform Guidance. All patients will be offered an application to participate in the sliding fee discount. Information will be entered into the system as declined or appropriate to arrive at the sliding fee category. The application will then come to Hampton where a billing clerk will review the application for accuracy. The CHC and Insurance tab will reflect the correct sliding fee category. Corrections to the patient account will be made if there are any inaccuracies found. Education will be provided to those making the error and corrective action taken if continued omissions. In the Organizations PMS, the slide is setup as an insurance, if no other insurance is primary the adjustment is automatically made. The PMS has been checked for accuracy of slide categories, adjustment codes and insurance types. Status update - Corrective action is in the process now. Each month the Billing Coordinator has begun 100% review of charts that have in-house lab preformed and preforming an audit to ensure the patient was offered the correct sliding fee. The 100% review began June 17, 2024 and will continue the review for 3 months. A second random audit will be conducted by the CIO monthly for during the 3 month period.

Categories

Special Tests & Provisions

Other Findings in this Audit

  • 497399 2024-001
    Material Weakness
  • 497400 2024-001
    Material Weakness
  • 1073840 2024-001
    Material Weakness
  • 1073841 2024-001
    Material Weakness
  • 1073842 2024-001
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
93.527 Grants for New and Expanded Services Under the Health Center Program $3.46M
93.224 Covid-19 Health Center Program (community Health Centers, Migrant Health Centers, Health Care for the Homeless and Public Housing Primary Care) $497,350
93.527 Covid-19 Grants for New and Expanded Services Under the Health Center Program $159,641
93.526 Grants for Capital Development in Health Centers $85,498