Views of Responsible Officials and Corrective Action Plan:
Proper implementation of the sliding fee policy is a critical component of operating a successful FQHC. Project HOME’s sliding fee policy complies with all local, state, and federal funding or regulatory requirements, including those defined by HRSA as part of the Health Center Program pursuant to Section 330 of the Public Health Service Act. The policy and related procedures were reviewed and found to comply at the most recent HRSA site visit in March 2024.
To address the identified deficiencies in oversight and effectiveness of controls related to the sliding fee discount income verification process, will implement the following actions:
1. Re-Training: Conduct comprehensive re-training sessions for all front desk team members on the sliding fee policies and procedures to ensure full understanding and compliance within 10 days for approved corrective action plan. Conduct an annual refresher training in the month of June.
2. Adherence to Controls: Reinforce adherence to all established controls outlined in the procedures, including the thorough review of all sliding fee discount program applications and income documentation.
a. ACCT Sliding Fee Discount, Fee Waiver, and Payment Plan Policy
b. ACCT Sliding Fee Discount, Fee Waiver, and Payment Plan Procedure
3. Monthly Audits: The Director of Operations will conduct monthly audits of the sliding fee discount program. This will involve random selection of applications to verify the accuracy of program documentation. Any identified errors will be promptly communicated to the VP of Health Services. All samples will be submitted to VP of Health Services for review.
4. Ongoing Audits: A designated member of the Project HOME accounting team will audit newly implemented sliding fee arrangements with patients. Any identified errors will be promptly communicated to the VP of Health Services and the Director of Operations.
5. Timely Re-Training: Upon identification of errors, necessary re-training for affected front desk team members will be addressed within one week of communication to ensure continuous compliance and improvement.
6. Corrective Action: Employees that are woefully non-compliant are subject to disciplinary action in accordance with Project HOME’s employee handbook. These actions aim to enhance oversight and ensure adherence to sliding fee policies and procedures, ultimately improving the effectiveness of the income verification process.