Finding 524220 (2024-001)

Significant Deficiency Repeat Finding

Requirement

Questioned Costs

Year

2024

Accepted

2025-02-21

Audit: 343418

Organization: Staywell Healthcare, Inc. (CT)

Auditor: Cohnreznick LLP

AI Summary

Core Issue: The Center failed to calculate sliding fee discounts accurately, leading to non-compliance with federal guidelines.
Impacted Requirements: The Center must adhere to the sliding fee scale based on patients' ability to pay, as mandated by DHHS regulations.
Recommended Follow-Up: Implement stronger internal controls to ensure accurate discount calculations and prevent future discrepancies.

Finding Text

Finding 2024.001: Special Tests and Provisions - Sliding Fee Scale Discounts - Significant Deficiency Grantor: U.S. Department of Health and Human Services Federal Program Names: Health Center Program Cluster: Community Health Centers COVID-19 Community Health Centers Affordable Care Act (ACA) Grants for New and Expanded Services Under the Health Center Program COVID-19 Affordable Care Act (ACA) Grants for New and Expanded Services Under the Health Center Program Federal Assistance Listing Numbers: 93.224 and 93.527 Federal Award Identification Number and Year: H800350 - 2023 and 2024, H8F41047 - 2021, H8G47675 - 2022, H8L51773 - 2023 Criteria Health centers are required to have a corresponding schedule of discounts applied and adjusted on the basis of patients' ability to pay and their eligibility. A patient's eligibility to pay is determined on the basis of the official poverty guideline, as revised by DHHS (42 CFR Sections 51c, 107(b)(5), 56.108(b)(5) and 56.303(f)). The Center should be implementing and monitoring procedures to properly determine, calculate and review sliding fee discounts issued to patients in accordance with the Center's sliding fee scale. Condition The Center did not always calculate the proper sliding fee discount based on approved policies. Cause The Center did not have adequate internal controls in place to effectively ensure that the patients received the correct sliding fee discount. Effect or Potential Effect The Center did not comply with the appropriate rules and regulations as per the Uniform Guidance. Questioned Costs None. Context A test of 40 sliding fee discount transactions was performed and resulted in four instances of a sliding fee discount not being properly calculated based on the respective patient family size and income. Our sample was a statically valid sample. Identification of Repeat Finding Yes - 2023.001. Recommendation The Center should establish a system of controls to ensure that all patients receive the correct sliding fee discount. Views of Responsible Officials and Planned Corrective Actions Management agrees with the audit finding and will strengthen internal controls and accountability to correct the deficiency.

Corrective Action Plan

SIGNIFICANT DEFICIENCY 2024.001 - Sliding Fee Scale Discount Recommendation The Center should implement a system of controls to ensure all sliding fee discounts are properly supported. Action Taken 1) To ensure Sliding Fee Discounts are properly supported, the Director of Program Management will assign random audits on a Monthly basis of patients that are assigned a sliding fee. 2) Director of Program Management as well as Program Managers will monitor Phreesia dashboard to identify self-pay patients on the schedule and work to ensure that accounts are updated accordingly. a. For any accounts that need to be updated, they will inform the PSA who checked in the patient to make the updates as necessary and provide additional training if needed. b. Provide trainings to PSAs to ensure that they are offering the Sliding Fee Discount to all patients that may need to apply, and appropriately applying those slides. 3) If a Pt has had a visit and left prior to getting sliding fee information, PSAs are to call the patient to let them know that they may have to apply for a sliding fee (or receive insurance information over the phone). 4) Practice Managers will identify Self-pay accounts via Phreesia each morning that may need attention and send a list of accounts to the PSAs at the beginning of each day. PSA will then contact the patients to remind them to bring in proof of income to apply for the sliding fee if eligilble.

Other Findings in this Audit

524221 2024-001

Significant Deficiency Repeat
524222 2024-001

Significant Deficiency Repeat
524223 2024-001

Significant Deficiency Repeat
524224 2024-002

Significant Deficiency
1100662 2024-001

Significant Deficiency Repeat
1100663 2024-001

Significant Deficiency Repeat
1100664 2024-001

Significant Deficiency Repeat
1100665 2024-001

Significant Deficiency Repeat
1100666 2024-002

Significant Deficiency

Programs in Audit

ALN	Program Name	Expenditures
93.268	Immunization Cooperative Agreements	$1.08M
93.914	Hiv Emergency Relief Project Grants	$798,263
93.918	Grants to Provide Outpatient Early Intervention Services with Respect to Hiv Disease	$368,698
93.870	Maternal, Infant and Early Childhood Home Visiting Grant	$322,619
14.231	Emergency Solutions Grant Program	$123,661
93.527	Affordable Care Act (aca) Grants for New and Expanded Services Under the Health Center Program	$75,041
93.153	Coordinated Services and Access to Research for Women, Infants, Children, and Youth	$68,035
93.243	Substance Abuse and Mental Health Services_projects of Regional and National Significance	$63,959
93.391	Activities to Support State, Tribal, Local and Territorial (stlt) Health Department Response to Public Health Or Healthcare Crises	$54,939
93.940	Hiv Prevention Activities_health Department Based	$27,055
93.224	Consolidated Health Centers (community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care)	$22,850
93.590	Community-Based Child Abuse Prevention Grants	$11,377
21.027	Coronavirus State and Local Fiscal Recovery Funds	$7,713