GREAT SALT PLAINS HEALTH CENTER

2019-001 Documentation Required for Sliding Scale Discounts Criteria: Under terms of its Grant Award from the U.S. Department of Health and Human Services the organization is required to annually establish a patient?s eligibility to receive a sliding scale discount for charges resulting from primary care services received by the patient. Additionally, the organization is required to maintain documentation of how this eligibility was established. Condition: During our tests of patient sliding scale discounts given during the year we noted several instances where a patient was assigned a sliding scale level without a proof of income and/or proper demographic information. We also noted where annual income calculations were incorrectly made potentially placing the patient in the wrong sliding scale level. Cause: The primary cause of the errors are lack of proper attention to obtaining correct documentation, ensuring that the documentation when obtained is correctly entered into the patient management system and consistent reinforcement of the center?s policies to both existing and replacement personnel. Effect or Potential Effect: By giving patients discounts on a sliding scale without proper documentation of income, demographics and improper calculation of income the organization is not full compliance of its grant agreement. Recommendation: Management should review all policies and procedures to ensure they are current and reflect proper operating conditions. All employees should be educated as often as necessary to ensure they understand what is required and self-audits should be performed frequently to provide assurance that the personnel are adhering to all operating requirements.

GSP HEALTH Better access. Better care. Better health. 405 S. Oklahoma Ave ? Cherokee, OK 73728 ? 580-596-2800 April 17, 2020 GSP Health Management Response to Audit Finding 2019-01: The following describes measures already completed, those in progress as of April 17, 2020, and those ongoing to assure compliance in the future. COMPLETED 1. The sliding fee policy was reviewed. During the review, it was noted that the language of the policy was consistent with the recommendations of the auditor to help avoid errors in processing the sliding fee determination for patients. The Sliding Fee Policy and Procedure is available upon request. 2. The Household Assessment (HHA) was consistently used by receptionists as the income level for patients. To eliminate the use of a patient's self-reported income as an accepted POI, this form has been modified to collect the data in a way that helps eliminate errors. IN PROGRESS 1. All patients with active sliding fees have been pulled from the Electronic Health Record (EHR) system. This amounted to 12,000 patients. The reception supervisors are working through every patient listed to determine the accuracy of the sliding fee determination. This will be completed by April 30th, 2020. 2. Initial re-training provided by the financial department covering the sliding fee discount program. This is to be completed by April 30th, 2020. Details of this training are available upon request. 3. Individual meeting with receptionist post-training. To be completed between May ist_ May 15th, 2020. 4. A training manual is being created with visual examples of the different Proof of Incomes (POI) a patient can provide. This will have pictures and guidelines to where the income is located on the POI and how the information should be entered into the EHR. This will be completed by May 31st, 2020. ONGOING 1. Ongoing monitoring of the sliding fee program will consist of the following: a. Daily Audits of 10 charts from all sites will be pulled by Front Desk Supervisors. This daily audit will continue until there are 3 months in succession that are 95% compliant with the sliding fee program. b. Monthly Audits of 50 charts will be performed by the Front Desk Supervisors. Results will determine individual training paths for employees. c. Sliding fee determination will be added to the quarterly billing training provided to the receptionists from the financial department . This section of the training will occur at EVERY quarterly meeting, regardless of the supervisor's monthly audit outcomes. Sincerely, Tim Starkey, MBA, FACHE Chief Executive Officer