FAC Explorer

Finding 9211 (2022-001)

Significant Deficiency
Requirement
N
Questioned Costs
-
Year
2022
Accepted
2024-01-19
Audit: 12576
Organization: Metro Community Health Centers, Inc. (NY)
Auditor: Bonadio & CO LLP

AI Summary

  • Core Issue: Discounts for eligible patients were not consistently applied according to the sliding fee discount schedule (SFDS).
  • Impacted Requirements: Health centers must ensure that charges are adjusted based on the SFDS, demonstrating compliance with their own policies.
  • Recommended Follow-Up: Revise processes to align with SFDS, provide staff training, and assign a dedicated reviewer for monthly compliance checks.

Finding Text

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 demonstrate adjustments to charges are consistent with the health center’s SFDS. Condition - We attempted to recalculate the applied discount using Metro Community Health Centers, Inc.’s policy and the patient documentation provided, noting instances where the adjustments to charges were inconsistent with Metro Community Health Centers, Inc.’s SFDS. Cause – SFDS discounts were inconsistently applied to services provided to individuals who attested to their eligibility. Effect - Out of our sample of 25 selections, we identified eight exceptions based on the SFDS. Recommendation - We recommend evaluating the current process and either changing it to match what is being done or provide education those involved in the process to adhere to Metro Community Health Centers, Inc.’s existing written policies and procedures in this area. We also encourage Metro Community Health Centers, Inc.’ to consider assigning a dedicated individual to regularly review the sliding fee visits to ensure compliance. This should be someone who is knowledgeable of the sliding fee requirements and Metro Community Health Centers, Inc.’s billing processes and procedures. View of Responsible Official – Metro Community Health Centers agrees that the sliding fee process needs to be revised and will implement procedures to match workflow. Additionally, Metro Community Health Centers will retrain all staff and assign a dedicated individual to perform monthly reviews.

Corrective Action Plan

The desired outcome of this corrective action plan is to retrain all staff working with the MCHC sliding fee discount scale and to have consistent and reliable application of the MCHC sliding fee discount scale to all eligible patients. Corrective Actions MCHC will implement a sliding fee discount schedule retraining program and engage all front desk staff, health center directors, and billing staff. Training will encompass all aspects of the sliding fee discount scale including but not limited to how individuals register, attest and apply the MCHC sliding fee discount scale. Retraining will be provided on a semiannual basis and include mock tests. This training program will be under the direct supervision of the Chief Operating Officer. All MCHC staff will be refamiliarized with the MCHC policy and procedures that relate to the Sliding Fee Discount Scale as part of the retraining process and will continue to review the Sliding fee discount program policy and procedure on an annual basis. The MCHC Sliding Fee Discount Scale and associated policy and procedure will be updated annually in accordance with policy, and we will ensure that the slide is provided to staff annually. A dedicated staff will be identified and assigned to do spot check reviews of the application of the sliding fee discount scale monthly and this will be implemented immediately. MCHC will provide an annual presentation on the Sliding Fee Discount Scale program to the MCHC Board of Directors that included annual updates to the program. The MCHC policies and procedures related to the Sliding Fee Discount Scale program will be revised to ensure inclusion of the above changes. Goal - Metro Community Health Center is committed to ensuring that we are compliant with all regulations as they relate to the Sliding Fee Discount Program. MCHC’s commitment moving forward is to perform more regular trainings as it relates to the sliding fee discount program as well as more regular review and testing of the program to ensure that the policies that are written are being appropriately applied and administered.

Categories

Eligibility

Other Findings in this Audit

  • 585653 2022-001
    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) $493,561
93.527 Affordable Care Act (aca) Grants for New and Expanded Services Under the Health Center Program $173,000
93.498 Provider Relief Fund $161,727