SPECTRUM HEALTH SERVICES, INC.Non-Profit

When Spectrum cut over to a new electronic health record in December 2019, the migration away from VRS (Centricity) to AthenaNet was unconventional and necessitated significant legal interaction. Spectrum identified the Centricity product as having deficiencies to the practice management system and especially to the reporting and financial aspect of the record. The only financial reporting that Spectrum was able to access were designed pivot tables out of the system that VRS controlled. The pivot tables were not able to be drilled down and any claims level reporting that we requested we also had to pay as a separate one-time fee. These reports sometimes ranged in the $2,000 to $3,000 range. When Spectrum was finally able to migrate away from Centricity, the legality of the separation left us with limited time for any conversion and an expensive process to migrate. Spectrum was able to transfer clinical notes, demographics, and zip codes but we were not successful transferring UDS, financial information or revenue cycle information. At the onset of the audit, Spectrum explained to BKD that we did not have access to any information from the Centricity system because of the limited information from our previous vendor due to the volatility of the separation. Spectrum has now been in AthenaNet for 18 months and the UDS, financial information and ability to report on dozens of different metrics is greatly improved. Unfortunately, due to the circumstances with the previous vendor and the limitation in the Centricity system, findings for sliding fee and documentation were unavoidable. Timeline- Already implemented and Spectrum staffing are continually trained to understand and administer the sliding fee program to qualifying patients. Responsible- The sliding fee program starts with operations and medical and dental integration at the front desk. The Director of Operations, the Clinical Director are responsible to ensure that call center and front desk team members are administering the program correctly. Senior management is responsible to monitor and make corrections as needed.

2019-002

As discussed in Finding 2020-02 above, When Spectrum was finally able to migrate away from Centricity, the legality of the separation left us with limited time for any conversion and an expensive process to migrate. Spectrum was able to transfer clinical notes, demographics, and zip codes but we were not successful transferring UDS, financial information or revenue cycle information. At the onset of the audit, Spectrum explained to BKD that we did not have access to any information from the Centricity system because of the limited information or our previous vendor due to the volatility of the separation. Spectrum has now been in AthenaNet for 18 months and the UDS, financial information and ability to report on dozens of different metrics is greatly improved. Unfortunately, due to the circumstances with the previous vendor and the limitation in the Centricity system, findings for sliding fee and documentation were unavoidable. Timeline- Already implemented and reporting capability is vastly improved. Responsible- CFO and Controller

2019-003

Spectrums management was fully aware that drawing down funds related to COVID funding earlier than expenses necessitated was a divergent funding strategy compared to the 330 grant funds. During our discussions with HRSA, there was little direction in the chaos of the moment. During the pandemic outbreak, Spectrum found itself in a very uncertain position. As medical offices were shutting down, Spectrum had no long-term assurance that telehealth funding was going to be available or how we were going to implement such a colossal change in such a volatile time. There were also significant discussions surrounding the funding and the current administration?s desire to pull back funding or limit its application or availability. These grant funds that were drawn down were kept in a non-interest bearing HRSA account and were not used by the health center until all of the funds were accounted for. The CFO and the CEO had immediate discussions with our HRSA program official and had 2 subsequent follow up meetings with HRSA to demonstrate our expenses and at that time HRSA passed the funding as acceptable and there was no further discussion needed. Timeline- Already implemented, ongoing Responsible- CFO and Controller.

Spectrum has taken the following action to halt, identify and correct these inaccuracies: Team Training Spectrum has conducted four separate trainings for all of our Managers, PSR?s and other operational staff The topics at these trainings covered: ? The overall philosophy and purpose of collecting accurate data ? The call centers role in scheduling the patient appointment and how to set the document expectations ? The importance of collecting all necessary forms and documents from patients in order to insert their financial status into Spectrums sliding fee scale. ? How to enter accurate information into all the applicable forms in the EHR ? What the end user data for both sliding fee and UDS data looks like and how this data translates into actionable information for HRSA Documented Trainings: ? PSR team meeting overview from 4/5/2019 as well as sign in sheet showing all PSR staff that participated in the training. One of the topics from the 4/5/2019 training was Sliding Fee Income. We addressed the proper way to obtain financial assessment information from patients. ? PSR team meeting overview from 6/21/2019 as well as sign in sheet showing all PSR staff that participated in the training. UDS demographics were addressed during this training session. We addressed how to enter financial assessment information into the UDS module in Centricity. We also addressed what to enter when patients do not provide financial information. ? PSR team meeting overview from 7/19/2019 as well as sign in sheet showing all PSR staff that participated in the training. The new sliding scale policies were addressed and reviewed in this meeting. Family Planning/Access Matters was also addressed in this meeting. The program no longer exists and patients here for family planning will be eligible for the normal medical sliding scale discounts. ? On 6/10/2019, all PSR staff were brought into the executive conference room to be instructed on the proper way to fee assess a Spectrum patient for sliding fee discounts. The VP of Human Resources, CFO, CMO, Site Manager, and Revenue Cycle Director were present for the entirety of this meeting. Staff were instructed that all patients are eligible for sliding fee discounts not just uninsured patients. Call Center Scripting and Training Spectrum recognizes that the process of documentation and effective data management starts with our call center staff. Spectrum has implemented a more prescribed and descriptive approach as to how we set these expectations with our patients. Our call center is now educating our patients and explaining the importance of bringing in income verification for our sliding fee scale. The new script addresses the idea that all patients are eligible for the sliding fee discounts, not just uninsured patients. Meaning, if insured patients provide proof of income they may be eligible for a discount on their copay, coinsurance, and/or deductible. The script also addresses the patient's right to decline the financial fee assessment. It further states that refusal to provide proof of income or financial information will result in the patient not being eligible for any discounts. Timeline- The timeline for corrective measures is ongoing but has been address in detail with our staff since April 2019. Responsible- There are multiple team members that are actively responsible for the documentation and preservation of these documents in the correct patient charts. Our revenue cycle director in correlation with our clinical supervisor are directly responsible to make sure that all patients are fee assessed the subsequent documentation is collected. Our patient financial counselor that was hired specifically to closely deal with uninsured patients will facilitate the sliding fee process with Spectrum?s population of uninsured. Ultimately, Spectrum views this as a measure that the CEO, CFO and CMO all hold responsibility to ensure this policy is adhered to closely. Training sheets, weekly internal audit form, UDS control form supporting documentation attached.

2018-002

Spectrum has highlighted this recommendation as a point of emphasis moving forward. Spectrum has formally address this finding in two separate policies that address the grants management process effective January 8, 2020 and a grant drawdown policy effective January 8, 2020. Spectrum has created a new grant drawn down template that highlights the drawdown timing and allows both the Controller and CFO to sign off on grant draw down. This will formalize the process that we previously in effect of the CFO emailing out the draw down timing and schedule. Timeline- The timeline for the grant process policies and drawdown are already in effect; the implementation of adherence to the new grant draw down document began on June 1, 2020 and is stored as a shared document on Spectrums internal serves allowing all finance staff to view and audit the document for timing and accuracy. Responsible- CFO and Controller. Updated Grants management policy and drawn down policy documents attached

GSA_MIGRATION

GSA_MIGRATION