Finding 9509 (2023-001)

Significant Deficiency Repeat Finding
Requirement
N
Questioned Costs
-
Year
2023
Accepted
2024-01-23

AI Summary

  • Core Issue: The Organization lacks proper documentation for sliding fee discounts, leading to non-compliance with federal guidelines.
  • Impacted Requirements: Internal controls are insufficient to ensure discounts are calculated based on patients' ability to pay and eligibility.
  • Recommended Follow-Up: Implement stronger internal controls to ensure all sliding fee discounts are accurately calculated and documented.

Finding Text

Grantor: U.S. Department of Health and Human Services Federal Program Names: Health Center Program Cluster: Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care), COVID-19 Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care), Grants for New and Expanded Services under the Health Center Program, COVID-19 Grants for New and Expanded Services under the Health Center Program Finding 2023.001: Sliding Fee Scale Documentation Federal Assistance Listing Numbers: 93.224 and 93.527 Health centers are required to have a corresponding schedule of discounts applied and adjusted on the basis of patients' ability to pay and their eligibility. A patient's eligibility to pay is determined on the basis of the official poverty guideline, as revised by DHHS (42 CFR Sections 51c, 107(b)(5), 56.108(b)(5) and 56.303(f)). The Organization should be implementing and monitoring procedures to properly determine, calculate and review sliding fee discounts issued to patients in accordance with the Organization's sliding fee scale. Condition The Organization did not always have the proper slide fee documentation readily available to ensure the proper slide fee discount was applied based on approved policies. Cause The Organization did not have adequate internal controls in place to effectively ensure that all sliding fee discounts were properly calculated based on approved documentation. Context A test of 40 sliding fee discount transactions was performed and resulted in 2 instances where the Organization was unable to provide approved documentation. Our sample was a statistically valid sample. Questioned Costs None Effect The Organization did not comply with the appropriate rules and regulations as per the Uniform Guidance. Identification of Repeat Finding Yes Recommendation The Organization should establish a system of internal controls to ensure that all sliding fee discounts are properly calculated and supported based on family size and income. Views of Responsible Officials and Planned Corrective Actions Management agrees with the audit finding and will strengthen internal controls and accountability to correct the deficiency. Health centers are required to have a corresponding schedule of discounts applied and adjusted on the basis of patients' ability to pay and their eligibility. A patient's eligibility to pay is determined on the basis of the official poverty guideline, as revised by DHHS (42 CFR Sections 51c, 107(b)(5), 56.108(b)(5) and 56.303(f)). The Organization should be implementing and monitoring procedures to properly determine, calculate and review sliding fee discounts issued to patients in accordance with the Organization's sliding fee scale.

Corrective Action Plan

To United States Department of Health and Human Services Heartland Community Health Center respectfully submits the following corrective action plan for the year ended April 30, 2023. CohnReznick, LLP 350 Church Street Hartford, CT 06103 Audit Period: April 30, 2023 The findings from the April 30, 2023 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the number assigned in the schedule. Federal Awards Findings: Finding 2023.001 - Sliding Fee Scale Discount Recommendation The Organization should establish a system of internal controls to ensure that all sliding fee discounts are properly calculated and supported based on family size and income. Action Taken • Monthly Audits o The Front Office Coordinators at each location will routinely audit sliding fee verification on a monthly basis to verify that information has been captured and recorded correctly and all proof of income documentation is received. These monthly audits will be adopted as standard protocol and procedure for front office operations, effective January 2024. Any findings through the audit process will be reported to the COO. At least five patien.t charts will be audited monthly. o In addition, the billing manager will also review audit findings or summaries to ensure adequate adjustment to patient accounts to correlate with the patient's eligibility status. • Staff Training o Although Heartland has offered periodic sliding fee scale procedure training, administration will be scheduling additional training with a focus on required documentation and proper set up of sliding fee discounts. o Health Center Practice Administrator will review and implement and update standard operating procedure for sliding fee scale verification. o Employees will receive a copy of the sliding fee scale policy and sign that they have read the material. o Front office employees at all locations will complete a sliding fee schedule competency check-off sheet that will be reviewed by the Front Office Coordinators and billing manager. If there are any question regarding this plan, please e-mail Regina Oxford at roxford@heartlandhealth.org. Sincerely,

Categories

Subrecipient Monitoring Eligibility HUD Housing Programs Internal Control / Segregation of Duties

Other Findings in this Audit

  • 9510 2023-001
    Significant Deficiency Repeat
  • 9511 2023-001
    Significant Deficiency Repeat
  • 9512 2023-001
    Significant Deficiency Repeat
  • 585951 2023-001
    Significant Deficiency Repeat
  • 585952 2023-001
    Significant Deficiency Repeat
  • 585953 2023-001
    Significant Deficiency Repeat
  • 585954 2023-001
    Significant Deficiency Repeat

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) $828,512
93.527 Affordable Care Act (aca) Grants for New and Expanded Services Under the Health Center Program $67,850
93.917 Hiv Care Formula Grants $58,836
93.243 Substance Abuse and Mental Health Services_projects of Regional and National Significance $54,706
93.461 Covid-19 Testing for the Uninsured $36,706
93.268 Immunization Cooperative Agreements $19,031
93.145 Aids Education and Training Centers $11,699
93.366 State Actions to Improve Oral Health Outcomes and Partner Actions to Improve Oral Health Outcomes $8,750