Regional Health Reach, Inc.

Management agrees with the finding. Deficiencies in the Sliding Fee Discount program for year ending December 31, 2022 are a direct result of several misfortunes. On top of the COVID pandemic, the organization experienced Unionization, de-Unionization, high staff turnover, including multiple changes in Senior Leadership, a death of an Executive Director, and an office relocation. Since January 2023, significant improvements have been implemented; the office settled into the new location, new staff and senior leaders have been hired, the organization is flourishing post-pandemic, and policies and procedures have been reviewed and updated. After review of the Sliding Fee Discount Program policies and office process, it was clear that previous controls were ineffective and identified gaps in the Sliding Fee Discount program structure. A major gap was the lack of knowledge related to who was in the current program and who continues to be eligible a year after acceptance. This gap was directly related to missing documentation, lack of EMR tracking, and lack of reporting. The previous corrective action for shelter, Street Medicine and Dental teams remains in place; providers who see patients? offsite were trained on the required documentation, which will be submitted to the clinic daily. Additional staff have been assigned to shelters to facilitate the registration process and transportation of the completed forms back to the Clinic for scanning. In mid-February 2023, an audit was completed on the Sliding Fee Discount program to determine clinic compliance. Additional gaps were identified which led to a secondary process of checks and balances. In addition to the current corrective action, a secondary corrective action was implemented. The Clinic staff would collect the application, review eligibility, and enter the approval/denial status, along with the date into the patients EMR, as well as entering the data on a spreadsheet to track yearly eligibility review. In addition, each team is equipped with a draft application that identifies the necessary information for a complete application. The controls currently in place are performed to identify eligibility at each appointment. If no change, the application is then filed until the next appointment or annual review date, whichever occurs first. If a patients income has changed, prior to the yearly review, a new application is completed at the time of visit, the EMR and spreadsheet are updated accordingly, and the application is filed. The current controls are reviewed daily in order to identify eligibility review and compliance.

2021-001

Management?s Response & Corrective Action Plan Management agrees with the finding. Controls have been put in place to ensure all new patients complete the Patient Application and Financial Sliding Fee Discount paperwork. Providers who see patients offsite at shelters have been retrained on the required documentation, which will be submitted to the clinic daily. Additional staff has been assigned to the shelters to facilitate the registration process and transportation of the completed forms back to the Clinic for scanning. These financial documents will be added to the patient?s electronic chart. For existing patients who are due for their annual financial recertification, a flag is placed in the electronic chart to complete the paperwork at their next visit. At the beginning of each month, a report that identifies patients seen the previous month will be used to identify compliance.