Finding 50560 (2022-001)

Significant Deficiency Repeat Finding
Requirement
N
Questioned Costs
-
Year
2022
Accepted
2023-05-23
Audit: 53034
Organization: Community Health Systems, Inc. (CA)
Auditor: Singerlewak LLP

AI Summary

  • Core Issue: Inappropriate sliding fee adjustments were given to patients, violating the organization's policy and federal requirements.
  • Impacted Requirements: Compliance with the sliding fee scale policy is essential for accurate billing and program income management.
  • Recommended Follow-Up: Ensure all staff are trained on the sliding fee policy, implement procedures for proper billing, and maintain documentation of patient eligibility for adjustments.

Finding Text

SECTION III ? FEDERAL AWARD FINDINGS AND QUESTIONED COSTS Finding 2022-001: PROGRAM INCOME ? CFDA #93.224 (Significant Deficiency in Internal Control over Compliance) Criteria: Per Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards at 2 CFR 200 (Uniform Guidance) for the Consolidated Health Centers grants, and per the grant agreement, centers are ?required to collect, or make every reasonable effort to collect appropriate reimbursement for their costs in providing health services to persons eligible for medical assistance.? Additionally, Health Centers are ?required to have a corresponding schedule of discounts applied and adjusted on the basis of the patient?s ability to pay.? Condition/Effect: A patient was given an inappropriate sliding fee adjustment under the Organization's policy. Out of the total number of patients (11,268) who received a sliding fee adjustment, a sample of 30 patients was tested. One patient received an inappropriate adjustment based on their eligibility. As a result, improper sliding fee adjustments were given. Questioned Cost: N/A Cause: Organization personnel were not appropriately following the sliding fee policy. Repeat finding: This is a repeat finding. Recommendation: Management should ensure all personnel are informed of the sliding fee scale policy and adhere to the requirements and guidelines set forth in the policy. Because the policy affects the program income, procedures should be implemented to ensure that all patients are billed the appropriate amount based on the sliding fee scale and only individuals who qualify under the policy guidelines receive sliding fee scale adjustments. Patient files should include documentation of eligibility for such adjustments. Views of responsible officials and planned corrective actions: The Operations Department continues to utilize its audit tool to conduct monthly internal audits of the Sliding Fee Discount (SFD) program. The Organization has continued seeing an upward trend in the monthly internal audits. The current year SFD finding is due to the system incorrectly applying the correct SFD slide. The Organization has reached out for technical assistance with its Practice Management System (PMS) in identifying why the slide was applied inaccurately. Billing Department was trained to set up the SFD schedule in the PMS?s library if there is any upgrades to the PMS system.

Corrective Action Plan

Finding 2022-001 PROGRAM INCOME ? CFD #93.224 (Significant Deficiency in Internal Control over Compliance) Response: Corrective Action Plan The Operation Department will conduct a verification of the sliding fee scale. In their internal monthly Sliding Fee Discount audit process, the Site Manager is to review and verify each patient application, to the current Federal Poverty Level, to ensure patient is receiving the correct discount. Attached is a copy of policy and procedure for this corrective action plan.

Categories

Allowable Costs / Cost Principles Cash Management Eligibility Significant Deficiency Program Income Internal Control / Segregation of Duties

Other Findings in this Audit

  • 627002 2022-001
    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) $6.71M
93.527 Affordable Care Act (aca) Grants for New and Expanded Services Under the Health Center Program $484,182
93.526 Affordable Care Act (aca) Grants for Capital Development in Health Centers $224,874