KONZA PRAIRIE COMMUNITY HEALTH CENTER, INC.Non-Profit

Health Center Program Cluster ? CFDA Nos. 93.224 and 93.527 U.S. Department of Health and Human Services Award No. 6 H80CS00210-19-06 Program Year 2020 Criteria or Specific Requirement ? Special Tests and Provisions: Sliding Fee Discounts (42 USC 254(k)(3)(g); 42 CFR sections 51c.303(g); and 42 CFR sections 56.303 (f)) Condition ? Certain patients received a sliding fee discount that was consistent with the stated sliding fee discount categories under the Organization?s policy, however, the policy was not in compliance with regulation concerning discounts provided based upon graduations of income for additional dental services. Certain other patients received a sliding fee discount that was inconsistent with the stated sliding fee discount policy. Questioned cost ? None Context ? A sample of 40 patients were tested out of the total population of 32,109 encounters. The sampling methodology used is not and is not intended to be statistically valid. Five patients received a sliding fee adjustment that was consistent with the approved policy for the proper sliding fee adjustments based on their income documentation, however, the policy was not compliant with the federal program requirements. Two patients received a sliding fee adjustment that was inconsistent with the approved policy for the proper sliding fee adjustment based on their income documentation. Effect ? Sliding fee discounts were given to patients that were inconsistent with the federal program requirements and inconsistent with the Organization?s sliding fee discount policy. Cause ? The Organization?s sliding fee policy did not comply with the Health Center Program Compliance Manual for certain services and the Organization did not comply with their sliding fee policy. Identified as a repeat finding, if applicable ? Is a repeat finding of findings 2019-001 and 2018-002. Recommendation ? We recommend management continue to ensure all personnel understand the sliding fee scale policy and adhere to the requirements and guidelines set forth in the policy. Procedures should be implemented to ensure that eligible patients receive discounts in accordance with the sliding fee scale and the Health Center Program Compliance Manual. Views of Responsible Officials and Planned Corrective Actions ? Management recognizes the importance of having sliding fee discount program that must meet the Health Center Program compliance manual and is consistent with project goals. The dental services and additional dental services sliding fee scale were updated with at least three discount pay classes based on the Federal Poverty Guidelines by Darrell Minton, Dental Billing/Front Desk Supervisor and Lee Wolf, CEO. Lee Wolf, CEO presented the updated dental sliding fee scale at the December 2020 board meeting for approval. It was approved and went into effect January 1, 2021.

Health Center Program Cluster ? CFDA Nos. 93.224 and 93.527 U.S. Department of Health and Human Services Award No. 6 H80CS00210-18-11 Program Year 2018 Criteria or Specific Requirement ? Special Tests and Provisions: Sliding Fee Discounts (42 USC 254(k)(3)(g); 42 CFR sections 51c.303(g); and 42 CFR sections 56.303 (f)) Condition ? Patients received a sliding fee discount that was consistent with the stated sliding fee discount categories under the Organization?s policy however the policy was not in compliance with regulation concerning discounts provided based upon graduations of income for dental services or patients received a sliding fee discount that was inconsistent with the stated sliding fee discount policy. Questioned cost ? None Context ? A sample of 40 patients were tested out of the total population of 34,443 encounters. The sampling methodology used is not and is not intended to be statistically valid. Eight patients received a sliding fee adjustment that was consistent with the approved policy for the proper sliding fee adjustments based on their income documentation however the policy was not compliant with the federal program requirements. The policy was corrected effective December 1, 2019. Five patients received a sliding fee adjustment that was inconsistent with the approved policy for the proper sliding fee adjustment based on their income documentation. Effect ? Sliding fee discounts were given to patients that were inconsistent with the federal program requirements and inconsistent with the Organization?s sliding fee discount policy. Cause ? The Organization sliding fee policy did not comply with Health Center Program Compliance Manual for certain services through November 30, 2019 and the Organization did not comply with their sliding fee policy. Identified as a repeat finding, if applicable ? Is not a repeat finding Recommendation ? We recommend management continue to ensure all personnel understand the sliding fee scale policy and adhere to the requirements and guidelines set forth in the policy. Procedures should be implemented to ensure that eligible patients receive discounts in accordance with the sliding fee scale and the Health Center Program Compliance Manual. Views of Responsible Officials and Planned Corrective Actions ? Management recognizes the importance of having sliding fee discount program that must meet the Health Center Program compliance manual and is consistent with project goals. The sliding fee scale was updated to comply with the Health Center Program Compliance Manual effective December 1, 2019. As noted in the audit sample, five patients were deemed by the auditor not updated retroactive during the year and received adjustments inconsistent with the approved policy based on their income documentation. The corrective action is deemed completed as of December 1, 2019. In reviewing the findings management found four of these encounters the patients were given the correct slide amount based on the policy. At the time of the visits the patient was given the correct slide, charged, paid, and billed correctly. In one of these cases Konza Prairie?s Practice Management System (PMS) created a system generated $5.00 SFS adjustment which was ultimately put back on the patients account, a $9.90 adjustment was written off as small balance adjustment and should have been adjusted off as a SFS adjustment. On one instance a billing staff member took the correct SFS adjustment of $154.00 and the patient was charged correctly. The billing staff member did not click finalize and the PMS automatically put the $154.00 back patients account, but the patient was never charged or billed for the amount. On the fourth patient the patient was given the correct slide at the time of the visit with 50% amount due. At the time of the visit and on the initial statement the patient was given the correct slide, charged, paid, and billed correctly. However, it was reversed by a new employee she changed the slide amount incorrectly. That is no longer employed at Konza Prairie. Management has hired an experienced medical certified biller and coder to supervise the medical billing and front desk staff, and promoted a dental billing staff member with over fifteen years of dental office management billing and coding experience to dental billing and front desk supervisor. These positions will provide training and oversight to the billing and front desk staff on the sliding scale policy and procedures. The training will include sliding scale determination documentation, discounts, charges, payments and communicating that information with the patient. These positions will also provide monthly patient account audits to determine that SFS patient accounts are accurate and up to date.

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