Finding 71662 (2022-004)

Material Weakness
Requirement
N
Questioned Costs
-
Year
2022
Accepted
2023-03-29

AI Summary

  • Core Issue: Health centers are not applying the sliding fee discount correctly based on patients' income levels, leading to inconsistent charges.
  • Impacted Requirements: Compliance with OMB 2 CFR 200, Subpart F, which mandates accurate sliding fee schedules for eligible patients.
  • Recommended Follow-Up: Enhance training for billing staff on sliding fee policies and ensure thorough reviews of patient accounts for proper documentation and discount application.

Finding Text

2022-004 Special Tests and Provisions Program Information Federal Organization U.S Department of Health and Human Services Assistance Listing Numbers 93.224 & 93.527 Health Center Program Cluster Award Numbers H80CS26623, H8FCS41667, H8DCS35811, H8HCS45016, C8ECS44852, C14CS39779 Criteria OMB 2 CFR 200, Subpart F Compliance Supplement, Part 4, Compliance Requirement N, Special Tests and Provisions states, ?Health Centers must prepare and apply a sliding fee discount schedule so that the amounts owed for health center services by eligible patients are adjusted (discounted) based on the patients ability to pay.? [X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness Condition During our testing of sliding fee discounts for health center patients qualifying for reduced charge visits, we identified several incidents in which the sliding fee applied was not consistent with the entities policies based on the patient?s level of income. Context This finding appears to be a systemic problem. A sample size of 25 patients included 10 who did not have the correct sliding fee applied. In addition, 7 of the 10 misapplied sliding fees were due to lack of application on file. Cause Due to turnover in the billing and admitting staff, there was lack of appropriate training relating to the requirements of the sliding fee system to properly administer the sliding fee program. Effect Patients may have been granted the incorrect sliding fee adjustment. Questioned Costs None identified. Recommendation We recommend continued effort in training personnel on applying the appropriate sliding fee discount based on the Organization?s approved policy and in compliance with the OMB Compliance Supplement requirements. An appropriate level of review should be conducted on patient accounts to ensure proper document retention, application of sliding fee discounts, and third-party insurance billing. Views of responsible officials and planned corrective action Management agrees with this finding. Management has already taken steps and has updated the clinic?s Sliding Fee Discount Program, the clinic?s fee schedule, and retraining of staff. See planned corrective actions in the next section of the Schedule of Audit Findings and Questioned Costs.

Corrective Action Plan

2022-004 Special Tests and Provisions Corrective action planned: In December 2022, the clinic reviewed and updated the clinic?s Sliding Fee Discount Program as well as the clinic?s fee schedule for 2023. We have trained staff and will be doing regular monitoring. We have made income and family size mandatory fields in the demographics field and requested that ECW to make sliding fee a mandatory field with a hard stop. Our data analyst is running regular reports to check if sliding fee is being done correctly with the billing liaison?s regular check of patient charts and billing, Policies and Procedures include monitoring of the Sliding Fee Discount Program. The billing liaison will randomly choose five charts from each clinic site to test patients? discount application, patient eligibility (income and family size), proof of income, and application of the appropriate sliding fee discount. Anticipated completion date: December 2022 Contact person responsible for corrective action: Elizabeth David, Finance Director

Categories

Special Tests & Provisions Material Weakness Significant Deficiency

Other Findings in this Audit

  • 71661 2022-003
    Material Weakness Repeat
  • 71663 2022-005
    Significant Deficiency
  • 71664 2022-003
    Material Weakness Repeat
  • 71665 2022-004
    Material Weakness
  • 71666 2022-005
    Significant Deficiency
  • 71667 2022-003
    Material Weakness Repeat
  • 71668 2022-004
    Material Weakness
  • 71669 2022-005
    Significant Deficiency
  • 648103 2022-003
    Material Weakness Repeat
  • 648104 2022-004
    Material Weakness
  • 648105 2022-005
    Significant Deficiency
  • 648106 2022-003
    Material Weakness Repeat
  • 648107 2022-004
    Material Weakness
  • 648108 2022-005
    Significant Deficiency
  • 648109 2022-003
    Material Weakness Repeat
  • 648110 2022-004
    Material Weakness
  • 648111 2022-005
    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 $1.86M
93.224 Consolidated Health Centers (community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) $952,805
93.498 Provider Relief Fund $330,097
93.011 National Organizations of State and Local Officials $273,334