Finding 8093 (2022-005)

Material Weakness
Requirement
N
Questioned Costs
-
Year
2022
Accepted
2024-01-10
Audit: 10646
Auditor: Wipfli LLP

AI Summary

  • Core Issue: Outreach Community Health Centers did not consistently apply the sliding fee discount schedule, leading to incorrect charges for patients.
  • Impacted Requirements: The health center failed to follow its own policies for calculating and documenting sliding fee discounts, affecting compliance with federal criteria.
  • Recommended Follow-Up: Establish stronger internal controls to ensure all sliding fee calculations are approved, documented, and reviewed for accuracy.

Finding Text

Finding 2022-005: Sliding Fee Assistance listing No. 93.224 Health Center Program Cluster Questioned Costs - N/A Criteria Health centers must prepare and apply a sliding fee discount schedule (SFDS) so that the amounts owed for health center services by eligible patients are adjusted (discounted) based on the patient’s ability to pay. The health center must also implement internal controls to ensure that the calculation is determined correctly and is supported. Condition Wipfli reviewed 40 sliding fee charges to test if the amount charged, was calculated properly based on the patients’ income level and in compliance with Outreach Community Health Center's’ sliding fee policy. Wipfli noted that 7 of the charges were not properly determined based on patients family size and income level, in addition Wipfli noted that 6 files did not contain approval of the sliding fee calculation. Cause and Effect Outreach Community Health Centers did not consistently follow the Organization’s policies for approving, documenting and calculating charges for services when using the sliding fee scale. As a result patients two patients were charged the improper sliding fee amount, one patient was included in the sliding fee program without documentation of family size or income, and the sliding fee discount was applied to four patient balances as Outreach Community Health Centers wrote off the account. Auditor’s Recommendation Implement effective internal controls that ensure that all policies and procedures related to the sliding fee are followed and that sliding fee discounts are reviewed to determine that the proper discounts were applied and documentation was retained or documented. Internal controls would include review and approval on alll slding fee determinations and a review of discounts given to sliding fee patients. View of Responsible Officials Management agrees with the findings and has committed to a corrective action plan.

Corrective Action Plan

Finding 2022-005: Sliding Fee Condition Wipfli reviewed 40 sliding fee charges to test if the amount charged, was calculated properly based on the patients’ income level and in compliance with Outreach Community Health Center's’ sliding fee policy. Wipfli noted that 7 of the charges were not properly determined based on patients family size and income level, in addition Wipfli noted that 6 files did not contain approval of the sliding fee calculation. Corrective Action Plan Re-education on proper completion of FPL fields provided to entire PSR staff 8/23/2023. Implementation of automated income calculation module within OCHIN Epic added 8/2023 OCHC created and filled Patient Financial Counselor position 11/27/2023 to monitor and update incomplete Sliding Fee Applications and audit quarterly for compliance. Person(s) Responsible PSR Manager – Lisa Mullins Director Revenue Cycle – Jennifer Leino Chief Financial Officer – Julia Harris Robinson Timing for Implementation 12/1/2023

Categories

Internal Control / Segregation of Duties

Other Findings in this Audit

  • 584535 2022-005
    Material Weakness

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) $4.45M
93.150 Projects for Assistance in Transition From Homelessness (path) $289,844
14.231 Emergency Solutions Grant Program $150,533
93.136 Injury Prevention and Control Research and State and Community Based Programs $100,570
14.235 Supportive Housing Program $97,476
93.667 Social Services Block Grant $62,145
93.958 Block Grants for Community Mental Health Services $60,487
14.267 Continuum of Care Program $40,563
93.558 Temporary Assistance for Needy Families $33,030