Finding 513846 (2023-002)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2023
Accepted
2024-12-11
Audit: 331851
Organization: Tca Health, Inc. (IL)

AI Summary

  • Core Issue: The organization failed to document patient eligibility for sliding fee discounts, impacting compliance with federal requirements.
  • Impacted Requirements: Health centers must evaluate patients based on income and family size to assign appropriate sliding fee categories.
  • Recommended Follow-Up: Management should enhance collaboration with vendors for accurate patient data and conduct regular internal audits to ensure compliance.

Finding Text

Federal Agency: U.S. Department of Health and Human Services Federal Program Title: Health Center Program Cluster Assistance Listing Numbers: 93.224 and 93.527 Federal Award Identification Number and Year: H80CS00109-21; H80CS00109-22 Award Period: May 1, 2022 – April 30, 2023; May 1, 2023 – April 30, 2024 Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance Criteria or specific requirement: Health centers must prepare and apply a sliding fee discount schedule so that the amounts owed for health center services by eligible patients are adjusted (discounted) based on the patient’s ability to pay. (42 USC 254(k)(3)(E), (F), and (G); 42 CFR sections 51c.303(e), (f), and (g); and 42 CFR sections 56.303(e), (f), and (g)). Condition: The Organization did not maintain documentation to show that patients had been evaluated for eligibility under its sliding fee scale policy and did not assign patients a sliding fee category. Questioned costs: None. Context: Twenty-five (25) of forty (40) encounters did not have current documentation of family size and income to assess sliding fee discount eligibility, and twenty-five (25) of twenty-five (25) were not assigned a sliding fee category. Cause: This matter was identified during a prior audit and corrected during the second half of calendar year 2023. As a result of when this matter was first identified, corrective active was not able to occur prior to the year ended June 30, 2023 audit. Corrective action occurring during the second half of calendar year 2023. Effect: Patients may not be assessed a correct sliding fee discount according to the Organization's sliding fee scale and their ability to pay. Repeat Finding: Yes, prior year finding 2022-003. Recommendation: Management should continue to work with its third-party vendors to ensure the accuracy and completeness of the patient information within its billing software in addition to continuing to conduct internal audits of patient visits to determine all required patient information has been obtained in accordance with TCA’s policies. Views of responsible officials: There is no disagreement with this finding.

Corrective Action Plan

The CFO at TCA Health has addressed the Special Provisions weakness by coaching and training front desk staff members. Specifically, staff were trained in the approved sliding fee scale policy and its requirements. The COO worked with the CFO and third-party billing company, and Athena to roll back the EMR update which contributed to ineffective application of the sliding fee in November 2023. TCA hired a full time Patient Services Manager in 2024 to support ongoing staff training, quality assurance monitoring, and implementation of the updated EMR and registration workflows. Staff have become proficient in the collection of data from patients, properly storing and recording it in the EMR, and the calculation of the slide according to the Federal Poverty Guidelines. Lastly, the team will be updated on the latest EMR module that experienced an upgrade and taught how to effectively apply the slide. Additionally, TCA began to undergo internal audits of records ensuring that proper documentation is maintained and a patient service manager, utilizing testing template provided by the organization’s auditor.

Categories

Eligibility Material Weakness Internal Control / Segregation of Duties

Other Findings in this Audit

  • 513847 2023-002
    Material Weakness Repeat
  • 1090288 2023-002
    Material Weakness Repeat
  • 1090289 2023-002
    Material Weakness 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) $3.40M
93.527 Affordable Care Act (aca) Grants for New and Expanded Services Under the Health Center Program $992,144
93.498 Provider Relief Fund $370,502
93.354 Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response $236,049
93.495 Community Health Workers for Public Health Response and Resilient $213,182
14.218 Community Development Block Grants/entitlement Grants $166,974
10.561 State Administrative Matching Grants for the Supplemental Nutrition Assistance Program $165,227
93.558 Temporary Assistance for Needy Families $164,580
93.332 Cooperative Agreement to Support Navigators in Federally-Facilitated and State Partnership Marketplaces $136,474
93.994 Maternal and Child Health Services Block Grant to the States $113,261
93.268 Immunization Cooperative Agreements $92,809
93.323 Epidemiology and Laboratory Capacity for Infectious Diseases (elc) $88,832
93.136 Injury Prevention and Control Research and State and Community Based Programs $82,277
10.557 Special Supplemental Nutrition Program for Women, Infants, and Children $58,070
93.526 Affordable Care Act (aca) Grants for Capital Development in Health Centers $48,117
10.572 Wic Farmers' Market Nutrition Program (fmnp) $997