Finding 499242 (2023-001)

Significant Deficiency
Requirement
N
Questioned Costs
-
Year
2023
Accepted
2024-09-28
Audit: 322048
Organization: Healthcore Clinic, Inc. (KS)

AI Summary

  • Core Issue: Patients received sliding fee discounts that did not match the organization's policy.
  • Impacted Requirements: Compliance with sliding fee discount criteria as outlined in federal regulations.
  • Recommended Follow-Up: Ensure staff are trained on the sliding fee scale policy and implement procedures for consistent application of discounts.

Finding Text

Health Center Program Cluster – CFDA Nos. 93.224 and 93.527 U.S. Department of Health and Human Services Award No. 5 H80CS33642-05-00 Program Year 2023 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 Organization’s policy. Questioned Cost – None Contact – A sample of 25 encounters out of 36,135 total encounters were tested and 2 errors were noted where patients received an incorrect sliding fee adjustment. The sampling methodology used is not and is not intended to be statistically valid. Two patients received a sliding fee adjustment that was inconsistent with the approved policy for the proper sliding fee adjustments based on their income documentation. Effect – Sliding fee discounts were given to patients that were inconsistent with the Organization’s sliding fee discount policy. Cause – The Organization did not comply with their sliding fee policy. Identification as a repeat finding, if applicable – Not applicable. Recommendation – We recommend 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

View of Responsible Officials and Planned Corrective Actions – In order to provide access to highquality healthcare regardless of one’s ability to pay, all of HealthCore Clinic’s services under its approved scope are offered on a sliding fee schedule. Patients eligible for HCC’s sliding fee scale have their charges discounted based on their slide level as determined by the sliding fee scale assessment. This audit revealed two errors with HCC’s application of the sliding fee scale resulting in incorrect charges or sliding fee write-offs. During 2023, HCC engaged Forvis Mazars to conduct a revenue cycle assessment and eClinicalWorks for revenue cycle optimization. The revenue cycle review highlighted areas for improvement and the revenue cycle optimization combed through HCC’s settings and workflows to ensure HCC’s EMR was configured and being used correctly. The revenue cycle optimization project helped HCC further automate its sliding fee scale so the correct amounts are automatically adjusted off of eligible claims. HealthCore Clinic will train all relevant staff on its sliding fee scale and how to correctly address and document additional adjustments and reversals. Additional internal audits will be completed to assess adherence to the sliding fee scale and other financial procedures. Organization contact persons responsible for corrective action: David Stowell, Chief Operating Officer Anticipated completion date: Revenue cycle projects were completed in early 2024; Additional retraining will be completed 9/4/2024; Additional audits will begin 8/30/24 and will be ongoing.

Categories

Special Tests & Provisions

Other Findings in this Audit

  • 499243 2023-001
    Significant Deficiency
  • 499244 2023-001
    Significant Deficiency
  • 499245 2023-001
    Significant Deficiency
  • 1075684 2023-001
    Significant Deficiency
  • 1075685 2023-001
    Significant Deficiency
  • 1075686 2023-001
    Significant Deficiency
  • 1075687 2023-001
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
93.527 Affordable Care Act (aca) Grants for New and Expanded Services Under the Health Center Program $191,576
93.224 Consolidated Health Centers (community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) $146,657
93.898 Cancer Prevention and Control Programs for State, Territorial and Tribal Organizations $61,523
93.268 Immunization Cooperative Agreements $36,179