MCC will take the following action to halt, identify and correct these inaccuracies. This is a new finding associated with the application of adjustment codes in the new billing system, EPIC. The previous year finding was errors with manual input by the front desk staff and was remediated. Patients were not charged incorrectly or more than the discount, and also there was no balance billed to the patient.
Adjustments of Sliding Fee Correction:
Based on the findings, patients paid less than the amount due under their discount class, and incorrect adjustment types were applied to the remaining balances.
To ensure accuracy going forward, all adjustments will use the correct adjustment codes for any remaining balances. These adjustments will follow a standardized process and include appropriate descriptions and categories within the system. If a patient cannot pay the difference between the discount class amount and their payment, the unpaid portion will be adjusted and written off as bad debt.
The remediation of this issue involves two main corrective actions. First, a correction has been made in the EPIC billing system to properly adjust bundled service codes and automatically write off incorrect bundle service fees. Second, a fix is being implemented to prevent the system from generating multiple billings due to the use of multiple sliding scale adjustment codes. Additionally, a rule has been set up to audit changes, ensuring that statements with sliding scale balances outside the normal range are held in the Statement Work Queue for review. The billing team will also undergo training to ensure accurate input of adjustments into the system.
Timeline – Training will be completed by end of Q3-FY25.
Completion: All trainings will be completed by end of Q3-FY25
Team Training
• MCC will continue to conduct trainings for all Clinic Managers, Front Office staff and Call Center staff.
• The topics at these trainings covered:
o The overall philosophy and purpose of collecting accurate data
o The importance of collecting all necessary forms and documents from patients in order to insert their financial status into MCC’s sliding fee scale.
o Definition of income; how to accurately calculate income.
o Definition of family size / household.
o The call center role in scheduling the patient appointments and how to set the document expectations.
o The importance of collecting all necessary forms and documents from patients in order to insert their financial status into MCC sliding fee scale.
o How to enter accurate information into all the applicable forms in the EHR.
o Operational workflow.
Team Training Timeline - the training will continue annually.
Completion: the training will be completed by end of Q3-FY25.
Internal Audits:
Timeline: Internal audit will be conducted on a monthly basis and findings will be discussed with clinic operation teams with the Interim Director of Billings and Interim Chief Financial Officer for corrective action.
Completion: We attest that monthly audits are implemented and discussed with clinic operations.
Responsible- There are multiple team members that are actively responsible for documentation and preservation of these documents in the correct patient charts: Clinic Manager, Front Office Supervisors, Director of Patient Services.
Ultimately, MCC views this as a measure that the Interim Chief Financial Officer and Interim Director of Billings all hold responsibility to ensure this policy is adhered to closely.
Contact person for Corrective Action Plan listed above:
Kathy Sonnenberg, Senior Compliance Coordinator
Tel: 415-755-2509
Email: ksonnenberg@marinclinic.org