Finding Number: 2023-001 Finding Type: Compliance - Special Tests and Provisions Information on the Federal Program: Program Name: Health Center Program Cluster (AL numbers 93.224 and 93.527) Grant Award: 2 H80CS00295-21 from March 1, 2022 through February 28, 2023 and 5 H80CS00295-22 from March 1, 2023 through February 29, 2024 Agency: U.S. Department of Health and Human Services, Health Resources and Services Administration Pass-Through Entity: N/A Criteria: In accordance with Section 330(k)(3)(G) of the PHS Act (42 U.S. Code § 254b), as an FQHC, the Organization must have a sliding fee discount program in which the Organization’s fee schedule is discounted based on a patient’s ability to pay. Condition Found and Context: The Organization has not applied sliding fee discounts to patient charges consistent with its sliding fee discount program. Through testing a statistically valid sample of transactions for the appropriate application of the Organization's sliding fee discount program to 53 individual patient balances, we noted the sliding fee discount applied was not consistent with the Organization's sliding fee discount policy for two patients. Based on income and family size, both patients qualified for a Level 2 discount category with a patient responsibility of $20 but were awarded and received a Level 1 discount with a patient responsibility of $15. Cause and Effect: Approval of the sliding fee discount applications involves manual processes and errors can occur. To help mitigate errors, the Organization has implemented monthly monitoring procedures which include the sampling of discounts provided to patient balances to ensure the appropriate discount level was awarded to the patient and the discount was appropriately applied to the patient's account consistent with the Organization's sliding fee discount program. The volume of discounts provided to patients annually does not allow for 100% review of all patient discounts and the inherent nature of sampling and as a result not all errors will be identified and corrected. It is possible the Organization may not apply sliding fee discounts to patient charges consistent with its sliding fee discount program. Questioned Costs: None Repeat Finding: No Recommendation: We recommend management management review the current process for approval of applications and update the process as deemed appropriate. We also recommend management provide additional training to the individuals involved in the approval process. We further recommend management consider increasing the number of transactions reviewed as part of the Organization's internal monitoring procedures. Views of a Responsible Official and Corrective Action Plan: Management agrees with the finding and will review the approval process and internal monitoring procedures for opportunities for improvement to increase compliance with the program requirements.
Condition Found: The Organization has not applied sliding fee discounts to patient charges consistent with its sliding fee discount program. Individual(s) Responsible for Corrective Action: Tina Gerlack, Billing Manager Planned Corrective Action: HealthFirst will continue to provide training on sliding fee eligibility to all staff related to sliding fee enrollment. HealthFirst will also continue to do monthly audits on all patients who receive a sliding fee discount. The monthly audits will include verifying the correct fee was applied based on documents received during the patients sliding fee enrollment. If any errors are found they will be immediately corrected. Anticipated Completion Date: 1/1/2024
Information on the Federal Program:Program Name: Health Centers Cluster (CFDA numbers 93.224 and 93.527) Grant Award: 5 H80CS00295-17 from March 1, 2018 through February 28, 2019 and 5 H80CS00295-18 from March 1, 2019 through February 29, 2020 Agency: U.S. Department of Health and Human Services, Health Resources and Services Administration Pass-Through Entity: n/a Criteria: In accordance with 42 USC 254(k)(3)(F), as an FQHC, the Organization must prepare and apply a sliding fee discount schedule so that the amounts owed for the Organization?s services by eligible patients are adjusted (discounted) based on the patient?s ability to pay. Condition Found and Context: The Organization has not applied sliding fee discounts to patient charges consistent with its sliding fee discount schedule. Through testing the application of the Organization's sliding fee policy to 25 individual patient balances, we noted the sliding fee discount applied was not consistent with the Organization's sliding fee discount policy for two patients. The total difference between the discount and the policy was less than 1% of the sample tested. Additionally, management was not able to provide sliding fee discount applications for three of the 25 patients tested. Cause and Effect: The errors were a result of human error where the patient responsibility under the Organization?s sliding fee discount program that was entered into the patients? records in the billing system did not agree with the approved sliding fee discount applications and contract with the two patients. The errors resulted in incorrect sliding fee discounts which resulted in patients paying less than required under the Organization sliding fee discount policy. Questioned Costs: None Repeat Finding: Yes (2018-001) Recommendation: We continue to recommend management develop and improve current monitoring processes for the sliding fee discount program to include independent verification of the discount calculation. Views of a Responsible Official and Corrective Action Plan: Management agrees with the finding. Documented reviews of sliding fee scale adjustments will continue to be completed to ensure compliance with the Organization's sliding fee discount policy.
Finding Number: 2019-001 Condition Found: The Organization has not applied sliding fee discounts to patient charges consistent with its sliding fee discount schedule. While testing the application of the Organization's sliding fee policy to 25 individual patient balances, we noted the sliding fee discount applied was not consistent with the Organization's sliding fee discount policy for two patients. The total difference between the discount and the policy was less than 1% of the sample tested. Cause: The errors were a result of the patient responsibility under the Organization's sliding fee discount program that was entered into the patients' records in the billing system not agreeing with the approved sliding fee discount applications and contract with the two patients due to a deficiency in monitoring procedures. The errors resulted in incorrect sliding fee discounts which resulted in patients paying less than required under the Organization sliding fee discount policy. Individual Responsible for Corrective Action: Ted Bolognani, CFO Corrective Action Planned: Step 1: At the beginning of each month, the Lead Accountant will run a monthly report from the billing program showing all sliding fee patients who have had a medical or BH encounter within the prior month. Step 2: The accounting assistant will use this Step 1 report to review the electronic billing record of each SFS patient seen in the prior month to verify HealthFirst has all documentation required; including the signed application, income verification, etc. and that the patients qualifying income is matched correctly to the sliding fee scale applied in the billing system. Step 3: If any documentation is missing or an incorrect sliding fee was applied to the patient?s visit this will be tracked on the billing report in step 1. Step 4: If any exceptions are found in step 3, the accounting assistant will notify the patient financial support & advocate staff of any errors so that documentation can be collected and scanned to patient record and will billing make any sliding fee corrections on the patient record as needed. Step 5: A monthly review of the Step 1 report and any notations made during the Step 3 review will be reviewed by CFO with the Practice Manager who oversees the patient financial support & advocate staff so that training is needed can occur and to insure no errors remain uncorrected. Anticipated Completion Date: Currently happening - February 2020
2018-001
Information on the Federal Program: Program Name: Health Center Program Cluster (CFDA numbers 93.224 and 93.527) Grant Award: 5 H80CS00295-17 from March 1, 2018 through February 28, 2019 and 5 H80CS00295-18 from March 1, 2019 through February 29, 2020 Federal Agency: U.S. Department of Health and Human Services, Health Resources and Services Administration Pass-Through Entity: n/a Criteria: In accordance with 2 CFR ? 180, Non-Federal entities are prohibited from contracting with parties that are suspended or debarred for the procurement of goods and services that are expected to equal or exceed $25,000. Condition Found and Context: The results of our testing of cash disbursement transactions identified the Organization did not perform procedures to verify that vendors were not debarred, suspended, or otherwise excluded. There were a total of 11 vendors with contracted amounts in excess of $25,000 during 2019. Cause and Effect: The Organization does not have formal written procedures to verify that vendors are not debarred, suspended, or otherwise excluded. If the Organization were to enter into a contract with an excluded vendor, any costs charged to the grant related to the contract would not be allowable and could result in questioned costs and loss of grant revenue. Questioned Costs: None Repeat Finding: No Recommendation: We recommend management develop procedures to verify that vendors are not debarred, suspended, or otherwise excluded. This verification would be accomplished by checking the vendor against the Excluded Parties List System maintained by the General Services Administration at sam.gov. Views of a Responsible Official and Corrective Action Plan: Management agrees with the finding. Formal policies and procedures will be established for the suspension and debarment compliance requirement.
Finding Number: 2019-002 Condition Found: The audit testing of cash disbursement transactions identified the Organization did not perform procedures to verify that vendors were not debarred, suspended, or otherwise excluded. There were a total of 11 vendors with contracted amounts in excess of $25,000 during 2019. Cause: The Organization does not have formal written procedures to verify that vendors are not debarred, suspended, or otherwise excluded. Individual Responsible for Corrective Action: Ted Bolognani, CFO Corrective Action Planned: HealthFirst just recently created a central purchasing position responsible for nearly all purchasing for the organization. This position reports to the CFO has been assigned the responsibility to verify that all new vendors any existing vendors over $25,000 in business are not debarred, suspended or otherwise excluded by checking the vendor against the Excluded Parties List on the GOA and SAM.gov websites. 1. All current vendors being used by HealthFirst above the $25,000 threshold have been checked and verified that they are not excluded. 2. Every 3 months this list of vendors will be re-checked. 3. Each verification will be documented and saved for audit review if required. 4. All new vendors, before business is conducted, will be checked against the Excluded Parties List and this check will be documented. 5. Any vendor discovered to be ?excluded? will be communicated immediately to CFO. CFO will block and future business with vendor and notify any staff conducting business with the vendor that an alternative vendor is required. Anticipated Completion Date: Currently happening - February 2020
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2017-001
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