THE FAMILY HEALTH CENTERS OF GEORGIA, INC.Non-Profit

Item 2022-001, Special Tests and Provisions - U.S. Department of Health and Human Services, Health Center Program Cluster (Assistance Listing Number 93.224/93.527/COVID-19 93.224) Criteria: Health centers are required to have a corresponding schedule of discounts applied and adjusted on the basis of the patient's ability to pay and their eligibility. A patient's eligibility and ability to pay is determined on the basis of the official poverty guidelines, as revised by HHC (42 CFR Sections 51c. 107(b)(5), 56.108(b)(5) and 56.303(f)). The Center should be implementing and monitoring procedures to properly determine, calculate and review sliding fee discounts issued to patients in accordance with the Center's sliding fee scale. Condition: When performing our audit, we noted the Center did not properly determine the sliding fee discount category given to certain patients selected for testing based on sliding fee scale in effect for the year ended May 31, 2022. Cause: There was deficiency in internal controls to ensure that proper documentation was obtained and that proper sliding fee discounts were being applied to patients in accordance with the Center's sliding fee scale. Effect: The Center did not comply consistently with the special tests and provisions compliance requirement based on the poverty guidelines in effect for the fiscal year 2022. In addition, the Center may not have properly calculated the sliding fee discount given to the patients and the discount given, if any, may not have been based on the patient's ability to pay. Questioned costs: None. Context: When performing our audit, we noted that the Center did not properly determine the sliding fee discount given to 3 out of 60 patients selected for testing based on the sliding fee scale in effect for the year ended May 31, 2022. Identification of Repeat Finding: Condition is repeat finding - see 2021-001. Recommendation: We recommend that proper training be given to employees and that sliding fee discounts be reviewed by a supervisor on a periodic basis to ensure compliance with the sliding fee scale. We recommend that the Center improve the implementation of their policy regarding keeping and maintaining the patient's proof of income or self-attestation regarding their income. View of Responsible Official: The Center revised its policies and procedures, trained its employees, and restructured the process for the sliding fee program, including strengthening monitoring and hired a new coordinator.

Item 2021-001, Special Tests and Provisions - U.S. Department of Health and Human Services, Health Center Cluster Programs (CFDA 93.224/93.527/COVID-19 93.224) Criteria: Health centers are required to have a corresponding schedule of discounts applied and adjusted on the basis of the patient's ability to pay and their eligibility. A patient's eligibility and ability to pay is determined on the basis of the official poverty guidelines, as revised by HHC (42 CFR Sections 51c. 107(b)(5), 56.108(b)(5) and 56.303(f)). The Center should be implementing and monitoring procedures to properly determine, calculate and review sliding fee discounts issued to patients in accordance with the Center's sliding fee scale. Condition: When performing our audit, we noted the Center did not properly determine the sliding fee discount category given to certain patients selected for testing based on sliding fee scale in effect for the year ended May 31, 2021. Questioned costs: None. Context: When performing our audit, we noted that the Center did not properly determine the sliding fee discount given to 6 out of 25 patients selected for testing based on the sliding fee scale in effect for the year ended May 31, 2021. Cause: There was deficiency in internal controls to ensure that proper documentation was obtained and that proper sliding fee discounts were being applied to patients in accordance with the Center's sliding fee scale. Effect: The Center did not comply consistently with the special tests and provisions compliance requirement based on the poverty guidelines in effect for the fiscal year 2021. In addition, the Center may not have properly calculated the sliding fee discount given to the patients and the discount given, if any, may not have been based on the patient's ability to pay. Identification of Repeat Finding: Condition is repeat finding - see 2020-001. Recommendation: We recommend that proper training be given to employees and that sliding fee discounts be reviewed by a supervisor on a periodic basis to ensure compliance with the sliding fee scale. We recommend that the Center improve the implementation of their policy regarding keeping and maintaining the patient's proof of income or self-attestation regarding their income. View of Responsible Official: Management agrees that the sliding fee discount has not been consistently applied to patients in accordance with the policy. The contributing factor was detected after the fiscal year end. The deficiency was an undetected computer software glitch within the billing module of the practice management system. The software glitch caused incorrect calculations resulting in the incorrect assignment of pay codes based on income and family size data that was inputted into the system. A trouble ticket was opened with the software vendor to report the error and the vendor has since corrected, tested, and accepted corrective action to resolve the issue. In addition to the computer software glitch, the medical center experienced an unexpected turnover in the Intake Supervisor position. Due to repeated turnover, training, monitoring, and tracking could not be performed timely. As a result, Executive management has upgraded the Intake Supervisor position to a Practice Manager position. Executive management is currently recruiting for the Practice Manager position. With the software correction, coupled with bringing a new Practice Manager on board, the finding is expected to be resolved during the fiscal year 2022.

Finding 2020-001: Sliding Fee Discounts: U.S. Department of Health and Human Services, Health Center Program Cluster: Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) (CFDA 93.224) and Grants for New and Expanded Services Under the Health Center Program (CFDA 93.527) Criteria: Health centers are required to have a corresponding schedule of discounts applied and adjusted on the basis of the patient's ability to pay and their eligibility. A patient's eligibility and ability to pay is determined on the basis of the official poverty guidelines, as revised by HHC (42 CFR Sections 51c. 107(b)(5), 56.108(b)(5) and 56.303(f)). The Center should be implementing and monitoring procedures to properly determine, calculate and review sliding fee discounts issued to patients in accordance with the Center's sliding fee scale. Statement of Condition: During our review of patient billing, 2 out of 25 samples selected for testing special tests and provisions compliance requirements had exceptions. The exceptions were due to the Center not properly determining the sliding fee discount category based on the sliding fee scale approved by the board. The sample size tested was a statistically valid sample size. Statement of Cause: There was deficiency in internal controls to ensure that proper documentation was obtained and that proper sliding fee discounts were being applied to patients in accordance with the Center's sliding fee scale. Effect: The Center did not comply consistently with the special tests and provisions compliance requirement based on the poverty guidelines in effect for the fiscal year 2020. In addition, the Center may not have properly calculated the sliding fee discount given to the patients and the discount given, if any, may not have been based on the patient's ability to pay. Questioned Costs: None Identification of Repeat Finding: No Recommendation: We recommend that proper training be given to employees and that sliding fee discounts be reviewed by a supervisor on a periodic basis to ensure compliance with the sliding fee scale. We recommend that the Center improve the implementation of their policy regarding keeping and maintaining the patient's proof of income or self-attestation regarding their income. View of responsible official: Management recognizes the need to ensure appropriate compliance with all sliding fee scale guidelines and will implement measures to ensure that all staff understand and are trained on collection of documentation from patients. A new supervisor has been employed, staff training, and monitoring is a part of the recently implemented action plan. In addition, there was a software glitch in the Practice Management System which caused incorrect sliding fee adjustments. The software system has now been corrected.

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