Family Health Services of Erie County

Finding 2024-001 – Sliding Fee Discount Program Federal Agency: U.S. Department of Health and Human Services Federal Program: Consolidated Health Centers Cluster AL Number: 93.224 / 93.527 Award Number: H80CS28351 Award Year: 2024 Repeat Finding: Yes Type of Finding: Significant Deficiency in Internal Control over Compliance and Noncompliance Criteria: Per Title 42 Chapter 1 Subchapter D Section 51c303(f)(g), “Health centers must have a schedule of fees or payments for the provision of their health services consistent with locally prevailing rates or charges designed to cover their reasonable costs of operation and a corresponding schedule of discounts adjusted on the basis of the patient’s ability to pay” and “Make every reasonable effort, including the establishment of systems for eligibility determination, billing, and collection.” Condition: During our special testing related to the Organization’s sliding scale, it was determined that the Organization did not consistently follow the sliding fee schedule in place. This occurred in three of the forty sampled patients. Cause: Review procedures were not followed within the Organization which caused issues in consistent application of the sliding schedule in accordance with the Organization’s policy. Effect: Potential that a patient would not receive the appropriate sliding fee discount or would receive a discount without meeting the discount criteria. Recommendation: We recommend the continued improvement of the process of billing encounters and analyzing claims to maximize the Organization’s program income and maintain compliance with the Sliding Fee Discount Program. Management’s Response: See Corrective Action Plan.

Finding Number: 2024-001 Anticipated Completion Date: January 31, 2025 Responsible Contact Person: David Tatro, CEO Planned Corrective Action: The Organization provided approximately 2,300 self-pay encounters to be audited for the year ended May 31, 2024. 40 encounters were identified for compliance testing related to the sliding fee. Three self-pay accounts were identified with issues which resulted in this finding. The issues related to patients receiving an improper discount rate. This issue will be resolved as of January 31, 2025 by reviewing all sliding fee scale applications for accuracy. The Organization will continue to monitor the sliding fee scale amounts applied to ensure ongoing compliance with the requirements. The Organization will review five sliding fee scale applications each week to ensure eligibility determination, billing and collection follows the Sliding Fee Discount Program. This will go through May 2025 with a reassessment at that point, based on the results of the internal review.

2023-001

Finding 2023-001 – Sliding Fee Discount Program Federal Agency: U.S. Department of Health and Human Services Federal Program: Consolidated Health Centers Cluster AL Number: 93.224 / 93.527 Award Number: H80CS28351 Award Year: 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria: Per Title 42 Chapter 1 Subchapter D Section 51c303(f)(g), “Health centers must have a schedule of fees or payments for the provision of their health services consistent with locally prevailing rates or charges designed to cover their reasonable costs of operation and a corresponding schedule of discounts adjusted on the basis of the patient’s ability to pay” and “Make every reasonable effort, including the establishment of systems for eligibility determination, billing, and collection.” Condition: During our special testing related to the Organization’s sliding scale, it was determined that the Organization did not consistently follow the sliding fee schedule in place. This occurred in one of the twenty sampled patients. Cause: Review procedures were not followed within the Organization which caused issues in consistent application of the sliding schedule in accordance with the Organization’s policy. Effect: Potential that a patient would not receive the appropriate sliding fee discount. Recommendation: We recommend the continued improvement of the process of billing encounters and analyzing claims to maximize the Organization’s program income and maintain compliance with the Sliding Fee Discount Program. Management’s Response: See Corrective Action Plan.

Finding Number: 2023-001 Anticipated Completion Date: May 2024 Responsible Contact Person: David Tatro, CEO Planned Corrective Action: The Organization provided 2,682 self-pay encounters to be audited for the year ended May 31, 2023. Out of the 2,682 self-pay encounters, 20 were identified for further review. Two self-pay accounts were identified with issues which resulted in this finding. The first issue was attributed to a patient inaccurately placed on a slide level, and the other patient account did not have an updated sliding fee scale application completed on file. This issue has been resolved as of November 2023 by reviewing all sliding fee scale applications for accuracy. The Organization will continue to monitor the sliding fee scale amounts applied to ensure ongoing compliance with the requirements. The Organization will review five sliding fee scale applications each week to ensure eligibility determination, billing and collection follows the Sliding Fee Discount Program. This will go through May 2024 with a reassessment at that point, based on the results of the internal review.

Finding 2020-001 ? Sliding Fee Discount Program Federal Agency: U.S. Department of Health and Human Services Federal Program: Consolidated Health Centers Cluster CFDA Number: 93.527 / 93.224 Award Number: H80CS28351 Award Year: 2020 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria: Per Title 42 Chapter 1 Subchapter D Section 51c303(f)(g), ?Health centers must have a schedule of fees or payments for the provision of their health services consistent with locally prevailing rates or charges designed to cover their reasonable costs of operation and a corresponding schedule of discounts adjusted on the basis of the patient?s ability to pay? and ?Make every reasonable effort, including the establishment of systems for eligibility determination, billing, and collection.? Condition: During our special testing related to the Organization?s sliding scale, it was determined that the Organization did not consistently follow the sliding fee schedule in place nor did it collect and maintain appropriate documentation from patients in order to verify that the amount discounted was appropriate. This occurred in three of the twenty sampled patients. Cause: There were changes in the billing process during the year, including changes to the sliding fee schedule, which caused issues in consistent application of the sliding schedule in accordance with the Organization?s policy. Effect: Potential that a patient would not receive the appropriate sliding fee discount. Recommendation: We recommend the continued improvement of the process of billing encounters and analyzing claims to maximize the Organization?s program income and maintain compliance with the Sliding Fee Discount Program. Management?s Response: See Corrective Action Plan.

Finding Number: 2020-001 Anticipated Completion Date: July 2020 Responsible Contact Person: David Tatro, CEO Planned Corrective Action: The Organization noted issues with the application of the sliding fee schedule application subsequent to year end and worked with the third party biller to resolve the issues. This was resolved by the Organization in July 2020. The Organization will continue to monitor the sliding fee amounts applied to ensure ongoing compliance with the requirements. The Organization will review five sliding fee scale applications each week to ensure eligibility determination, billing and collection is in compliance with the Sliding Fee Discount Program.

2019-004

Finding 2019-004 ? Sliding Fee Discount Program Federal Agency: U.S. Department of Health and Human Services Federal Program: Consolidated Health Centers Cluster CFDA Number: 93.527 / 93.224 Award Number: H80CS28351 Award Year: 2019 Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance Criteria: Per Title 42 Chapter 1 Subchapter D Section 51c303(f)(g), ?Health centers must have a schedule of fees or payments for the provision of their health services consistent with locally prevailing rates or charges designed to cover their reasonable costs of operation and a corresponding schedule of discounts adjusted on the basis of the patient?s ability to pay? and ?Make every reasonable effort, including the establishment of systems for eligibility determination, billing, and collection?. Condition: There are various conditions related to this finding: 1 ? During our special testing related to the Organization?s sliding scale, it was determined that the Organization did not consistently follow the sliding fee schedule in place nor did it collect and maintain appropriate documentation from patients in order to verify that the amount discounted was appropriate. This occurred in five of the twenty sampled patients. 2 ? During our testing of program income, it was determined that the Center incurred a significant amount of untimely filed claims during the year ended May 31, 2019, resulting in lost revenue. There were also many encounters that lacked the proper insurance coverage documentation. Cause: There was a breakdown in the billing process that did not require or allow the billing staff to consistently apply the sliding schedule in accordance with their policy for several patients and did not maintain documentation supporting the schedule used for other patients. Effect: Potential that a patient would not receive the appropriate sliding fee discount. Recommendation: We recommend the continued improvement of the process of billing encounters and analyzing claims to maximize the Organization?s program income and maintain compliance with the Sliding Fee Discount Program. Management?s Response: See Corrective Action Plan.

Finding Number: 2019-004 Anticipated Completion Date: 10/1/2019 Responsible Contact Person: David Tatro, CEO Planned Corrective Action: The CEO/CFO has updated the sliding fee scale to reflect the 2019 federal poverty guidelines and has posted it on their website and ensured that all patients attestations occur. FHS staff have been given collection procedures and resources. The billing department and clinical team are monitoring the processes and ensuring that all appropriate patients are reviewed based on the sliding fee scale.

2018-004

GSA_MIGRATION

GSA_MIGRATION