Finding Text
Health Center Program Cluster ? CFDA Nos. 93.224 and 93.527 U.S. Department of Health and Human Services Award No. 2 H80CS33642-04-00 Program Year 2022 Criteria or Specific Requirement ? Special Tests and Provisions: Sliding Fee Discounts (42 USC 254(k)(3)(g); 42 CFR sections 51c.303(g); and 42 CFR sections 56.303 (f)) Condition ? Patients received a sliding fee discount that was inconsistent with the stated sliding fee discount categories under the Organization?s policy. Questioned cost ? None Context ? A sample of 40 patients were tested and 2 errors were noted where patients received an incorrect sliding fee adjustment. The sampling methodology used is not and is not intended to be statistically valid. Two patients received a sliding fee adjustment that was inconsistent with the approved policy for the proper sliding fee adjustments based on their income documentation. Effect ? Sliding fee discounts were given to patients that were inconsistent with the Organization?s sliding fee discount policy. Cause ? The Organization did not comply with their sliding fee policy. Identification as a repeat finding, if applicable ? Is a repeat finding of 2021-001. Recommendation ? We recommend management continue to ensure all personnel understand the sliding fee scale policy and adhere to the requirements and guidelines set forth in the policy. Procedures should be implemented to ensure that eligible patients receive discounts in accordance with the sliding fee scale and the Health Center Program Compliance Manual. Views of Responsible Officials and Planned Corrective Actions - In order to ensure the Sliding Fee discounts are consistently calculated and applied to patients? accounts, Thrive changed the EMR set up to increase automation in September 2021, which reduced manual transactions and potential Slide Fee errors. Thrive continues to review and have discussions of the Sliding Fee policy and procedures with the outsourced billing company who are aware of, and understand, and are following them to the best of their abilities. Beginning in January 2023, the billing company began monitoring the creator of and the accuracy of slide adjustments. This will be done by running a report of slide adjustments in the month and spot checking 20-30 accounts for accuracy. Comments will be made on the monthly list and saved. Any concerns will be investigated. Other procedures already in place to monitor sliding fee discounts include monthly audits which began September 2021. These audits are conducted by Carmen Fortson, Director of Patient Access and Natoris Harris Patient Access Manager. This year they audit 5 charts per provider and will increase that by choosing another 5 charts at random for additional testing. They review the sample for sliding fee discounts applied to them, the correct insurance information, documentation of proof of income, and correct Federal Poverty Limit designation, and discount calculations. Any discrepancies are investigated and providers and management are educated in best practices. The monthly review also includes an internal audit of client records to identify any patients that have provided the proper proof of income qualify for the sliding fee discount that are not receiving the discount. If this situation occurs, training will be conducted by Carmen or Natoris with their staff to ensure the patients who are qualified are receiving the discounts.