HEALTH SERVICES INC

Plan of Action: The area of compliance evaluated relates to the area of organizational workflow that includes patient intake. Due to the severity of this issue, management has implemented the following as a corrective action:  Contact granting organization for technical assistance with implementing and maintaining compliance during a period of increased staffing shortages and turnovers  Redesigned current workflow and office procedures to include the following changes: o Entry Level intake will only involve information gathering and collection of copays o 1st Level Supervision will review data and determine eligibility of sliding fee and application. The supervisor will also review the application to ensure that all signatures and demographic data has been included. o 2nd Level Supervision will perform random chart audits Monthly o 3rd Level Supervisor will perform random chart audits Quarterly  All patient intake staff will receive one-on-one training on Sliding Fee and the importance of documentation.

2023-002

The area of compliance evaluated relates to the area of organizational workflow that includes patient intake. Due to the severity of this issue, management has implemented the following as a corrective action: Contact granting organization for technical assistance with implementing and maintaining compliance during a period of increased staffing shortages and turnovers  Redesigned current workflow and office procedures to include the following changes: o Entry Level intake will only involve information gathering and collection of copays o 1st Level Supervision will review data and determine eligibility of sliding fee and application o 2nd Level Supervision will perform random chart audits Monthly o 3rd Level Supervisor will perform random chart audits Quarterly  All patient intake staff will receive one-on-one training on Sliding Fee and the importance of documentation.

2022-001

Finding 2022-001 ? Special Tests and ProvisionsThe auditee acknowledges the findings of the auditors. It has been noted that two patients were billedat discounts above eligibility levels and one patient was billed at a discount below the eligible amount.Review of the samples noted revealed that one of the 3 individuals included in the finding occurredas a result of staff inputting the incorrect salary information into the system for those patients and/ornot selecting the proper frequency for patient income, i.e., monthly, weekly, biweekly, annually, etc.These are simple human errors that occur when staff are inundated with tasks during registrationmissing detailed steps as they enter the patient?s income.Another instance of the noted error existed as a result of the staff failing to include the income for allindividuals in the household income calculation which provided a greater than applicable discount.The final error occurred as a result of failure to follow up and adjust patient accounts for those patientswho present and apply for the sliding fee. This patient applied for the sliding fee discount at the timeof the visit, but because he did not have the income verification, he was listed as self-pay and givena 30 day notice to provide the information. The patient paid toward the balance and once he providedinformation it was determined that his payment on the day of the visit exceeded the required paymentper the sliding fee. Supervisors failed to adjust the account and provide the patient with a refund, asa result patient?s account did not reflect the proper discount.Plan of Action:Management reviewed the findings and began to rationalize the reasons that these findings occurredand measures that will help to reduce these errors. The course of action to be taken includes thefollowing to be implemented immediately:? Reduction of Turnover in PAR. A contributing factor to the errors with sliding fees is turnoverin the department. There is a considerably high percentage of turnover average of 6%. Errorsare existing due to the turnover of staff, and the constant training.? Strengthened procedures for Supervisors of employees registering patients are nowcompleting audits of patients? charts to review the sliding fee scale and the attacheddocumentation. The audits are conducted on the patient account as they present for service.Because of the nature of the Sliding Fee Program, the documentation required toparticipated, and the setup of our Patient Management System (Athena), these areperformance audits and are based on how accurate each employee enters information intothe system.? Training to reiterate avoiding common mistakes while registering patients and workingwith patient information.? Also, as recommended, we have scheduled a date to renew the annual sliding fee scaleand notify patients. As an added measure, we will also commit to documenting the effectivedates for any leniency in the corresponding Board minutes.

2021-002

Management?s Response: : Management acknowledges that during the current year and after notification of the initial condition in the prior year audit, management established, through corrective actions, a process to ensure that the sliding fee would be applied according to the established sliding fee policy. The items tested in the noted conditions occurred prior to implementation of the corrective action plan resulting from the prior year?s audit. ? Explanation of conditions noted during testing: ? 2 patients where listed in the incorrect income bracket. Human error in calculating income and/or identifying the correct monthly income. Turnover and staff shortages have contributed these errors. The organization is consistently struggling with managing the staffing shortages and turnovers. The organization has at least 2 refresher trainings during the year and when applicable, one-one training with staff who fall below guidelines. Note: This was corrected through the efforts and implementation of the corrective action plan from prior year; however, it did not show as corrected at the time of occurrence because the service date tested was prior to the implementation date. See Corrective action below. ? 2 patients were still under 2017 plan. Failure to follow procedures. The 2 patients noted were registered by the same individual who failed to follow the proper procedures to change the plan year on the sliding fee. The patients received the proper sliding fee discount, but the system used to capture the information did not show the proper year since the registering individual failed to cancel the previous year. Instead the sliding fee program information was updated on the old year which is how it displayed on the account. Note: This was corrected through the efforts and implementation of the corrective action plan from prior year; however, it did not show as corrected at the time of occurrence because the date in question was prior to the implementation date. See corrective action below.? 1 patient did not return income documentation and therefore not eligible. Patients are provided services regardless of their ability to pay. Patient?s requesting to participate in the sliding fee program are allowed to apply for the sliding fee program even if they do not have all the required income documentation on the day of service. Those patients are given a 30 day notice to return the corrected information or be responsible for the entire bill. The patient did not return for service and did not provide the income information as requested, thus making him responsible for the full bill. The patient bill was not adjusted when he failed to return. This is a process that requires specific staff training addressed in the corrective plan below. ? 1 patient?s discount was applied to their balance after they made their co-pay. Patients wishing to participate in the sliding fee program often bring a minimum payment on the initial date of service regardless of the knowing how much or the total cost of the service for that visit or the required documentation. The initial payment is applied to the patient?s account at the time of service and the patient is given a 30 day request for required income documentation. When that documentation is submitted, the proper sliding fee discount is applied. In the condition noted, the patient provided income documentation after the initial visit and the sliding fee adjustment was provided; however, because the proper procedure of removing all payments from the account was not followed by the individual applying the sliding fee, the sliding fee adjustment was applied to the remaining balance due instead of the entire cost of service. This is a process that requires specific staff training addressed in the corrective plan below. Corrective Action: Management suggests the following corrective action to reduce or eliminate the findings above: ? Reduction of Turnover in PAR. A contributing factor to the errors with sliding fees is turnover in the department. There is a considerably high percentage of turnover average of 6%. Errors are existing due to the turnover of staff, and the constant training. ? Strengthen procedures to include audits of patients? charts focusing on the sliding fee scale and the attached documentation. The audits are conducted on the patient account as they present for service. Hired Staff dedicated to review of the patient charts and to perform audits of patients. ? Increased training to help reduce/avoid common mistakes made while registering patients.

2020-001

Management?s Response: Management acknowledges the condition as stated. Management began using its current financial system to track grant costs. A breakdown in the process, included the full allocation of 2 invoices containing, both allowable and non-allowable costs, to the grant. Management corrected the error in allocation in the system and implemented the following corrective action in the grant costing procedures: Corrective Action: Management has strengthened its processes for allocating grant costs. All parties involved in purchasing, recording, or paying any costs associated with grants will submit requisitions that only contain allowable costs. These requests will be submitted independent of any other daily operation requests. Also, staff involved in the payment and reimbursement of grant costs have been issued copies of the budget for the current grants and the allowable costs for those grants. Staff has also been informed of the guidelines for grant costing and how to correctly identify/track those costs in the financial system. As an added measure, prior to submitting any costs for reimbursement the CFO and Sr. Account will review the submission to ensure that costs submitted for reimbursement are eligible grant costs.

Finding 2020-001 ? Special Tests and ProvisionsThe auditee acknowledges the findings of the auditors. It has been noted that two patients were billed atdiscounts above eligibility levels and one patient was billed at a discount below the eligible amount.Review of the samples noted revealed that one of the 3 individuals included in the finding occurred as aresult of staff inputting the incorrect salary information into the system for those patients and/or notselecting the proper frequency for patient income, i.e., monthly, weekly, biweekly, annually, etc. Theseare simple human errors that occur when staff are inundated with tasks during registration missingdetailed steps as they enter the patient?s income.Another instance of the noted error existed as a result of the staff failing to include the income for allindividuals in the household income calculation which provided a greater than applicable discount. Thefinal error occurred as a result of failure to follow up and adjust patient accounts for those patients whopresent and apply for the sliding fee. This patient applied for the sliding fee discount at the time of thevisit, but because he did not have the income verification, he was listed as self pay and given a 30 daynotice to provide the information. The patient paid toward the balance and once he provided information itwas determined that his payment on the day of the visit exceeded the required payment per the slidingfee. Supervisors failed to adjust the account and provide the patient with a refund, as a result patient?saccount did not reflect the proper discount.Plan of Action:Management reviewed the findings and began to rationalize the reasons that these findings occurred andmeasures that will help to reduce these errors. The course of action to be taken includes the following:? Reduction of Turnover in PAR. A contributing factor to the errors with sliding fees is turnover in thedepartment. There is a considerably high percentage of turnover average of 6%. Errors are existing dueto the turnover of staff, and the constant training.? Strengthened procedures for Supervisors of employees registering patients are now completing auditsof patients? charts to review the sliding fee scale and the attached documentation. The audits areconducted on the patient account as they present for service. Because of the nature of the Sliding FeeProgram, the documentation required to participated, and the setup of our Patient Management System(Athena), these are performance audits and are based on how accurate each employee entersinformation into the system.? Training to reiterate avoiding common mistakes while registering patients and workingwith patient information.? Also, as recommended, we have scheduled a date to renew the annual sliding fee scaleand notify patients. As an added measure, we will also commit to documenting theeffective dates for any leniency in the corresponding Board minutes.

2019-003

Finding 2019-003 ? Special Tests and ProvisionsCorrective Action:The auditee acknowledges the findings of the auditors. It is noted that two patients were billed at discounts above eligibility levels and one patient was billed at a discount below the eligible amount. This is due to staff inputting the incorrect salary information into the system for those patients and/or not selecting the proper frequency for patient income, i.e., monthly, weekly, biweekly, annually, etc.The patient noted whose account was never adjusted, sent in his income after the expiration of the 30 day policy waiting period to return the income. Upon providing the required documentation, staff failed to follow through and request that the account be adjusted to reflect the proper discount.The final item noted in the listing of findings included a patient whose appointment was scheduled prior to the change in minimum fee. The Board of Directors approved the minimum fee change in a meeting at the end of February 2018. In order, to give patients proper notice the minimum fee did not go into effective until April 2018, in efforts to allow patients with appointments in March 2018 notice. The finding states that the patient was charged an incorrect minimum fee, the patient was allowed to pay the previous fee and not the increased price which was to be effective in April.Plan of Action:Management reviewed the findings and began to rationalize the reasons that these findings occurred and measures that will help to reduce these errors. The course of action to be taken includes creating procedures in patient registration that involves increased audits and reviews of patient accounts. As well as, increased training to reiterate avoiding common mistakes when calculating patient incomes and sliding discounts. We will also work to implement the minimum fee changes in a more, timely manner.

GSA_MIGRATION

GSA_MIGRATION

GSA_MIGRATION