Finding 497598 (2023-003)

Significant Deficiency

Requirement

Questioned Costs

Year

2023

Accepted

2024-09-23

Audit: 320377

Organization: William F. Ryan Community Health Center, Inc. (NY)

Auditor: Bonadio & CO LLP

AI Summary

Core Issue: Ryan Health's discounts for eligible patients were not consistently applied according to the sliding fee discount schedule (SFDS).
Impacted Requirements: Required documentation was often missing or outdated, leading to incorrect adjustments in charges.
Recommended Follow-Up: Implement more frequent training for staff and appoint a dedicated individual to oversee the sliding fee process and ensure compliance.

Finding Text

Criteria - Health centers must prepare and apply a sliding fee discount schedule (SFDS) so that the amounts owed for health center services by eligible patients are adjusted (discounted) based on the patient’s ability to pay. The health center must demonstrate adjustments to charges are consistent with the health center’s SFDS. Condition - We attempted to recalculate the applied discount using Ryan Health’s policy and the patient documentation provided, noting instances where the adjustments to charges were inconsistent with Ryan Health’s SFDS. Cause - Lack of controls to ensure that staff are obtaining required documentation and entering the information correctly. Effect - Out of our sample of 20 selections, we identified eleven exceptions based on the SFDS. Seven of the discounts entered lacked the required slide documentation, the slide form had expired and was not updated, or the document was updated, but the data in the system was not resulting in the slide that was provided not being supported or applied incorrectly. Four of the discounts were improperly adjusted during the billing or review process based on insurance or payments received, or incorrect charges being calculated and applied to the total slide for the remaining patient balance. Recommendation - Providing the sliding fee to patients is a requirement of specific grant funds received. As such, we recommend Ryan Health review the current procedures in place and consider additional and more frequent training for all employees involved in the process. We encourage management to consider appointing an individual at the various locations to assist the front desk staff with the sliding fee process to ensure required documentation is captured and recorded accurately in the billing system. We also encourage Ryan Health to consider assigning a dedicated individual to regularly review the sliding fee visits to ensure compliance. This should be someone who is knowledgeable of the sliding fee requirements and Ryan Health’s billing processes and procedures.

Corrective Action Plan

Management response - Verification of income and assignment of sliding fee categories are the responsibility of the Patient Services staff. Over the last few years, we have experienced significant turnover in that area. In addition, we have implemented electronic registration, both onsite (through the use of kiosks) and offsite (using the Luma remote registration and communication platform). As a result, a significant cohort of patients conducts a self-registration. This requires new workflows to ensure correct assessment and documentation. Ryan Health has implemented an extensive training program for "front desk" staff and supervisors under the leadership of the new Chief Operating Officer and his site management team. This in person training includes pre training and post training assessments, permanent resources available online and ongoing reinforcement. In addition, reports are available in real time by site and down to the individual patient service representative level to evaluate completion of all required data points. In addition, Ryan will be implementing an internal audit function by the end of the current fiscal year to monitor compliance with the sliding fee requirements. If there are any additional questions, please contact Jose J. Virella, Chief Financial Officer at jose.virella@ryanhealth.org at 212-769-7245.

Other Findings in this Audit

497599 2023-003

Significant Deficiency
497600 2023-003

Significant Deficiency
497601 2023-003

Significant Deficiency
497602 2023-003

Significant Deficiency
497603 2023-003

Significant Deficiency
497604 2023-003

Significant Deficiency
1074040 2023-003

Significant Deficiency
1074041 2023-003

Significant Deficiency
1074042 2023-003

Significant Deficiency
1074043 2023-003

Significant Deficiency
1074044 2023-003

Significant Deficiency
1074045 2023-003

Significant Deficiency
1074046 2023-003

Significant Deficiency

Programs in Audit

ALN	Program Name	Expenditures
10.557	Special Supplemental Nutrition Program for Women, Infants, and Children	$3.49M
93.493	Congressional Directives	$2.00M
93.268	Immunization Cooperative Agreements	$1.68M
93.498	Provider Relief Fund	$859,892
93.526	Affordable Care Act (aca) Grants for Capital Development in Health Centers	$754,921
93.918	Grants to Provide Outpatient Early Intervention Services with Respect to Hiv Disease	$690,312
93.217	Family Planning_services	$285,265
93.917	Hiv Care Formula Grants	$239,771
93.527	Affordable Care Act (aca) Grants for New and Expanded Services Under the Health Center Program	$41,606
93.224	Consolidated Health Centers (community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care)	$21,759
93.994	Maternal and Child Health Services Block Grant to the States	$15,484