FAC Explorer

Finding 7450 (2023-001)

Significant Deficiency
Requirement
N
Questioned Costs
-
Year
2023
Accepted
2024-01-04
Audit: 9608
Organization: Primary Health Care, Inc. (IA)
Auditor: Forvis LLP

AI Summary

  • Core Issue: Patients received sliding fee discounts that did not match the Organization's policy categories.
  • Impacted Requirements: Compliance with sliding fee discount policies as outlined in federal regulations.
  • Recommended Follow-Up: Ensure all staff understand and follow the sliding fee scale policy; implement procedures for consistent application of discounts.

Finding Text

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 25 patients were tested out of the total population of 147,293 encounters. The sampling methodology used is not and is not intended to be statistically valid. Three 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 – Not a repeat finding. 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.

Corrective Action Plan

Management's action plan to improve compliance includes a formal review of Primary Health Care's sliding fee discount policies to assure policies are consistent with Uniform Guidance, to be lead by Kelly Huntsman, Chief Executive Officer with support of Nathan Simpson, Chief Operating Officer, Julie Raasch, Chief Quality Officer, Dr. Heidi Shreck, Chief Medical Officer, and Beth Frantum, Chief Financial Officer to be completed in January 2024. If revisions are necessary, Kelly will bring them to the Board of Directors for approval in January 2024. Samantha Kohls, Patient Services Director, will then lead the process of updating resource materials associated with sliding fee discounts and distribute them to necessary staff. Samantha will then provide training to necessary staff on any revised sliding fee discount policy and any changes.

Categories

Special Tests & Provisions

Other Findings in this Audit

  • 7451 2023-001
    Significant Deficiency
  • 7452 2023-001
    Significant Deficiency
  • 7453 2023-001
    Significant Deficiency
  • 583892 2023-001
    Significant Deficiency
  • 583893 2023-001
    Significant Deficiency
  • 583894 2023-001
    Significant Deficiency
  • 583895 2023-001
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
93.224 Consolidated Health Centers (community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) $3.69M
32.006 Covid-19 Telehealth Program $952,232
64.033 Va Supportive Services for Veteran Families Program $759,335
14.267 Continuum of Care Program $652,750
21.023 Emergency Rental Assistance Program $593,816
93.918 Grants to Provide Outpatient Early Intervention Services with Respect to Hiv Disease $590,067
93.498 Provider Relief Fund $468,127
14.241 Housing Opportunities for Persons with Aids $365,738
93.917 Hiv Care Formula Grants $341,615
93.217 Family Planning_services $325,713
93.493 Congressional Directives $300,000
93.527 Affordable Care Act (aca) Grants for New and Expanded Services Under the Health Center Program $254,158
93.268 Immunization Cooperative Agreements $185,181
14.239 Home Investment Partnerships Program $141,960
93.391 Activities to Support State, Tribal, Local and Territorial (stlt) Health Department Response to Public Health Or Healthcare Crises $133,091
14.231 Emergency Solutions Grant Program $131,229
93.011 National Organizations of State and Local Officials $111,265
93.940 Hiv Prevention Activities_health Department Based $102,819
93.526 Affordable Care Act (aca) Grants for Capital Development in Health Centers $96,000
93.243 Substance Abuse and Mental Health Services_projects of Regional and National Significance $92,955
93.150 Projects for Assistance in Transition From Homelessness (path) $39,557
21.027 Coronavirus State and Local Fiscal Recovery Funds $24,574
93.270 Adult Viral Hepatitis Prevention and Control $8,107