Oakland Integrated Healthcare Network, INC.

2023-001, 2022-001 - MATERIAL WEAKNESS AND MATERIAL NONCOMPLIANCE - SLIDING FEE Contact Person – Patricia Fournier, CFO Completion Date – 02/01/2024 Finding – We tested 60 sliding fee encounters and noted that 10 out of 60 patients were discounted, charged or adjusted the wrong amount and 4 out of 60 patients sliding fee applications had documentation issues. The Organization failed to verify sliding fee applications were obtained for all patients receiving discounts and incorrectly applied sliding fee discounts to charges. We recommend the Organization continue with the corrective action plan implemented in the prior year in response to audit finding 2022-001 to ensure sliding fee applications are completed before encounters are billed. We recommend that management continue to review and monitor the internal sliding fee application auditing process for further improvements and consider increasing sample sizes. RESOLUTION: 1.Staff Training. Honor continued in-depth monthly trainings for front-end processes. The training includes patient check-in, insurance verification, and sliding fee application completion. We determined through our audit process that health centers without a clinical receptionist continued to have issues. We expanded our training to include all employee classes that complete patient check-in This includes CHWs, BHCs, and call center staff. Participants complete a test to ensure the necessary knowledge and skills were obtained during the training. If the participant’s score is under our benchmark, they will complete the training again. All staff also complete the training as part of new employee on-boarding and participate in the all staff annual update training. 2.Dashboard Reporting. Honor Practice Managers use a daily dashboard to monitor prior day visits to ensure that all patient check-in, insurance verification, and sliding fee applications information is input correctly. 3.Monthly Audit & Follow-up. The Revenue Cycle Manager will publish a monthly report to include all sliding fee applications. The report will be sent on the 15th of the month for the prior month. The report will include all sliding fee applications by location that are not in compliance. The Practice Managers will work with staff to address and correct these applications. The RCM will publish a subsequent report on the 30th of the month to ensure all sliding fee applications have been corrected and are in compliance. Any location with remaining sliding fee application out of compliance on the 30th will report to their immediate supervisor to correct the sliding fee applications. 4.Sliding Fee Application Workflow. Honor worked with a consultant to review the sliding fee workflow process from patient registration through patient payment. With our review we identified processes to implement within the EHR that will automate steps in the workflow to eliminate errors in the entry process. We also updated the payment posting process to auto write-off the remaining balance of the encounter at the time of the patient payment.

2022-001, 2021-001

2022-001, 2021-001 - MATERIAL WEAKNESS AND MATERIAL NONCOMPLIANCE - SLIDING FEE - Contact Person - Patricia Fournier, CFO Completion Date - 11/01/2022. Finding ? We tested 60 sliding fee encounters and noted that 3 of 60 sliding fee encounters tested did not have sliding fee applications, 13 out of 60 patients were discounted the wrong amount, 2 out of 60 patients sliding fee applications could not be located. We recommend the Organization continue with the corrective action plan implemented in the prior year in response to audit finding 2021-001 to ensure sliding fee applications are completed before encounters are billed. We recommend that management continue to review and monitor the internal sliding fee application auditing process for further improvements and consider increasing sample sizes. Response and Resolution: RESOLUTION: 1. Staff Training. The onset of COVID, staff turnover, and the abrupt implementation of Telehealthcaused some gaps in the adherence of processes such as sliding fee application updates. Honordeveloped and implemented an in-depth monthly training for front-end processes. The trainingincludes patient check-in, insurance verification, and sliding fee application completion. Participantscomplete a test to ensure the necessary knowledge and skills were obtained during the training. If theparticipant?s score is under our benchmark, they will complete the training again. This training isrequired for all front-end staff and practice managers. Staff will complete the training as part of newemployee on-boarding. Staff will also be required to complete an annual update training. 2. Dashboard Reporting & Sample Testing. A need for more immediate accountability was determinedin review of the clinic site infrastructure. Honor developed and implemented a daily dashboard to beused by the Practice Manager to monitor prior day visits to ensure that all patient check-in, insuranceverification, and sliding fee applications information is input correctly. In addition, the dailydashboards are audited by our Risk Management team weekly and the number of reviews will beincreased to 25% of the total weekly charts. These audits include verifying the sliding fee applicationis completed correctly with a signature, the slide was input correctly in the EHR, and a proof of incomeis attached. These weekly audits are accumulated monthly and reported to management for review.A new workflow process will be developed to ensure that appropriate on-site staff view the slideinformation in the EHR to ensure it matches the sliding fee application and proof of income. 3. Review Current Policy and Application ? Honor will review the current sliding fee application and policy. The review will include a patient survey to determine if our application is appropriate for our patient population to complete. Honor will also determine if requiring proof of income is a barrier to care for our patients. Management will explore all Federal, State and local regulations and guidelines to ensure our policy stays within these regulations.

2021-001

2022-002 - MATERIAL WEAKNESS AND MATERIAL NONCOMPLIANCE - FRINGE BENEFITS Contract Person - Patricia Fournier, CFO Completion Date - 10/01/2022 Finding - We noted fringe benefits were charged based on a flat budgeted percentage rather than actual expenses. We recommend that fringe benefits be charged to grants based on the actual expenses to ensure costs are allowable and do not result in a potential takeback of funds. Response and Resolution: RESOLUTION: Honor revised the process for allocating and recording fringe benefits in our accounting system. Incoming vendor invoices for fringe benefits are posted to a pre-paid account until the time for the cost to be recognized as an expense. Actual fringe benefit costs are recognized as an expense with each payroll. The fringe benefit cost is allocated by employee to the appropriate location and funding source at the time of payroll. These actual expenses are then reported on all funder financial summary reports.

Contact Person - Patricia Fournier, CFO; Completion Date - 03/31/2022; Finding ? We tested 40 sliding fee encounters and noted that 4 of the 40 sliding fee encounters tested did not have sliding fee applications, 3 out of the 40 sliding fee applications were not approved by a staff member and 2 out of the 40 patients were discounted the wrong amount. We recommend that sliding fee applications be completed and properly approved for each sliding fee patient. Procedures should be implemented to verify applications are completed before the encounter is billed. In addition, the Organization could consider doing sampling throughout the year to verify sliding fee applications are obtained, completed, and agree to the discount applied. Response and resolution: 1. Staff Training. As a result of COVID, staff turn over and the abrupt implementation of Telehealth caused some gaps in the adherence of processes such as sliding fee application updates. RESOLUTION: Honor developed and implemented an in-depth training for front-end processes. The training includes patient check-in, insurance verification, and sliding fee application completion. Participants complete a test to ensure the necessary knowledge and skills were obtained during the training. If the participant?s score is under our benchmark, they will complete the training again. This training is required for all front-end staff and practice managers. Staff will complete the training as part of new employee on-boarding. Staff will also be required to complete an annual update training. 2. Dashboard Reporting & Sample Testing. A need for more immediate accountability was determined in review of the clinic site infrastructure. RESOLUTION: Honor developed and implemented a daily dashboard to be used by the Practice Manager to monitor prior day visits to ensure that all patient check-in, insurance verification, and sliding fee applications information is input correctly. The Practice Managers are doing daily audits of the sliding fee applications to ensure they are completed properly.