Finding 57884 (2022-001)

Significant Deficiency
Requirement
N
Questioned Costs
-
Year
2022
Accepted
2023-01-29

AI Summary

  • Core Issue: The Organization lacks proper documentation for sliding fee discounts based on patients' income and family size.
  • Impacted Requirements: Compliance with the Uniform Guidance for sliding fee discount policies is not being met.
  • Recommended Follow-Up: Implement stronger internal controls to ensure all sliding fee discounts are properly documented and supported.

Finding Text

Finding 2022.001: Sliding Fee Scale Documentation Grantor: U.S. Department of Health and Human Services Federal Program Names: Health Center Program Cluster: Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care), Grants for New and Expanded Services under the Health Center Program Federal Assistance Listing Numbers: 93.224 and 93.527 Criteria In accordance with the Uniform Guidance, the Organization must prepare and apply a sliding fee discount policy and schedule so that the amounts owed for health center services by eligible patients are adjusted (discounted) based on a patient's poverty level, which is determined by the patient's income and family size. Condition The Organization did not always have the proper documentation on file to support the patient's income and family size. Context A test of 25 sliding fee discount transactions was performed and resulted in 15 instances where the Organization was unable to provide approved documentation. Our sample was a statistically valid sample. Questioned Costs None. Cause The Organization did not have adequate internal controls in place to effectively ensure that the proper sliding fee discount information is on file and illustrates the appropriate discount based on the Organization's sliding fee discount policy. Effect The Organization did not comply with the appropriate rules and regulations as per the Uniform Guidance. Identification of Repeat Finding No. Recommendation The Organization should establish a system of internal controls to ensure that all sliding fee discounts are properly supported. 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

Corrective Action Plan Year Ended April 30, 2022 To United States Department of Health and Human Services Heartland Community Health Center respectfully submits the following corrective action plan for the year ended April 30, 2022. CohnReznick, LLP 350 Church Street Hartford, CT 06103 Audit Period: April 30, 2022 The findings from the April 30, 2022 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the number assigned in the schedule. Federal Awards Findings: Finding 2022.001 - Sliding Fee Scale Discount Recommendation The Center should establish a system of internal controls to ensure that all sliding fee discounts are properly calculated. Action Taken ? Monthly Audits o The immediate supervisor of front office operations will routinely audit sliding fee verification on a monthly basis to verify that information has been captured and recorded correctly. These monthly audits will be adopted as standard protocol and procedure for front office operations, effective January 2023. Any findings through the audit process will be reported to the COO. At least five patient charts will be audited monthly. o In addition, the billing manager will also review audit findings or summaries to ensure adequate adjustment to patient accounts to correlate with the patient?s eligibility status. ? Staff Training o Although Heartland has offered periodic sliding fee scale procedure training, administration will be scheduling additional trainings with a focus on required documentation and proper set up sliding fee. o Supervisor of front office operations will review and implement and update standard operating procedure for sliding fee scale verification. o Employees will receive a copy of the sliding fee scale policy and sign that they have read the material. o Front office employees at all locations will complete a sliding fee schedule competency check-off sheet that will be reviewed by the immediate supervisor and billing manager. If there are any question regarding this plan, please e-mail Scott Burcher at sburcher@heartlandhealth.org. Sincerely, Scott Burcher Chief Financial Officer

Categories

HUD Housing Programs Internal Control / Segregation of Duties

Other Findings in this Audit

  • 57885 2022-001
    Significant Deficiency
  • 57886 2022-001
    Significant Deficiency
  • 634326 2022-001
    Significant Deficiency
  • 634327 2022-001
    Significant Deficiency
  • 634328 2022-001
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
93.527 Affordable Care Act (aca) Grants for New and Expanded Services Under the Health Center Program $1.60M
93.224 Consolidated Health Centers (community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) $1.45M
93.526 Affordable Care Act (aca) Grants for Capital Development in Health Centers $1.00M
93.268 Immunization Cooperative Agreements $162,653
93.498 Covid-19 Provider Relief Fund and American Rescue Plan (arp) Rural Distribution $162,451
93.917 Hiv Care Formula Grants $53,110
93.145 Aids Education and Training Centers $27,147
93.461 Covid-19 Hrsa Covid-19 Claims Reimbursement for the Uninsured Program and the Covid-19 Coverage Assistance Fund $24,960