Finding Text
Finding Number: 2022-001 Finding Type: Compliance - Special Tests and Provisions Information on the Federal Program: Program Name: Health Center Program Cluster (AL numbers 93.224 and 93.527) Grant Award: 4 H80CS00554-20 from March 1, 2021 through February 28, 2022 and 6 H80CS00554-21 from March 1, 2022 through February 28, 2023 Agency: U.S. Department of Health and Human Services, Health Resources and Services Administration Pass-Through Entity: N/A Criteria: In accordance with Section 330(k)(3)(G) of the Public Health Service Act (42 U.S. Code ? 254b), as an FQHC, the Organization must have a sliding fee discount program in which the Organization?s fee schedule is discounted based on a patient?s ability to pay. Condition and Context:The Organization has not applied sliding fee discounts to patient charges consistent with its sliding fee discount program. Through testing a statistically valid sample of transactions for the appropriate application of the Organization's sliding fee discount program to 25 individual patient balances, noted one patient did not have a valid application in effect for the date of service tested. Cause and Effect: The Organization had a major Electronic Health Records (EHR) information system upgrade during the year and the process for verification of valid sliding fee discount applications within the EHR changed. The patient previously had a valid sliding fee discount application but discount expiration date was no longer easily identifiable in the EHR by the patient intake staff due to the upgrade and the patient visit noted as a sliding fee discount eligible visit. As a result, the patient was given a $124 discount without a valid sliding fee application. The Organization has implemented monthly monitoring procedures which include the review of sliding fee applications and sampling of discounts provided to patients to help ensure patients receive discounts in accordance with the Organization's sliding fee discount policy. The volume of discounts provided to patients annually does not allow for 100% review of all patient discounts and the inherent nature of sampling will not result in all errors will be identified and corrected. As a result, it is possible the Organization may not apply sliding fee discounts to patient charges consistent with its sliding fee discount program. Questioned Costs: None Repeat Finding: No Recommendation: We recommend management provide training to individuals involved in the patient intake and billing processes specific to the EHR process changes and to modify internal monitoring procedures to include an emphasis in the sampling on changes in processes or staffing. We further recommend specific procedures be development as part of the internal monitoring to verify discounts were not provided to patients with recently expired discounts. Views of a Responsible Official and Corrective Action Plan: Management agrees with the finding and has implemented additional training and will update monitoring procedures to increase compliance with program requirements.