HIDALGO MEDICAL SERVICES

Current Year Findings Corrective Action Plan 2023-001 Improper application of sliding fee discount CFDA Nos. – 93.224 and 93.527 Federal Award ID # and Year – 5 H80CS00744-21-00 Program Year 2023 Federal Agency Name: U.S. Department of Health and Human Services Type of finding Significant deficiency in internal control over compliance (recurring) Criteria or Specific Requirement Special Tests and Provisions: Sliding Fee Discounts per Title 42 Chapter 1 Subchapter D Section 51c303(f) Condition The Organization’s sliding fee program provides discounts on patient services based upon the individual’s level of income. However, the Organization applied the incorrect discount based upon the individual’s income per the Organizations sliding fee discount policy. Cause Clerical error in applying the sliding fee discount adjustment in the billing system for the patient. Effect or Potential Effect Improper sliding fee discounts given to patients. Questioned Costs None Context or Perspective Information A sample of 40 patients were tested out of the total population of 2,283 encounters. The sampling methodology used is not statistically valid. Two patients received the incorrect sliding fee discount based upon their income level. Recommendation We recommend that the Organization implement a verification process to ensure the sliding fee discounts being applied are in accordance with their sliding fee policy. Corrective Action Plan Hidalgo Medical Services (HMS) will implement an enhanced training program to ensure the sliding fee discounts are applied in accordance with the current sliding fee policy. A comprehensive re-training of current Patient Financial Services (PFS) Claims Reviewing staff will occur by December 2023. A training manual will be developed to include competency validation for each Claims Reviewer staff person, and the new training model will be used for all future Claims Reviewer staff. In addition, HMS will continue to use the training manual for all incoming Community Health Workers to ensure the sliding fee assessment continues to stay in compliance. 35 Main Clinic & Administration P.O. Box 550 530 DeMoss Street Lordsburg, NM 88045 Secondly, HMS will implement an enhanced training program and verification process to ensure the sliding fee discounts are applied in accordance with the current sliding fee policy. The Claims Reviewer Supervisor will randomly select at least 30% of SFS patient visits monthly to ensure billing adjustment accuracy. HMS has been working diligently over the last year to improve the sliding fee assessments, and all proper documentation has been obtained (the new auditing requirement will occur immediately). There were no findings this year on assessments, and we will apply a similar audit process and follow-up action plan to the billing adjustment process. Also, all errors found will be fixed right away. The Claims Reviewer Supervisor will report each month to the Chief Operating Officer (COO) the audit results, and the COO will report to the Chief Executive Officer (CEO) any findings and required corrections, if applicable. In addition, the Finance Director will continue randomly auditing the sliding fee assessments each month to ensure compliance with the program. The Chief Financial Officer will report each month to the CEO any findings and required correction, if applicable. Person Responsible: Sonia Jacquez, Claims Reviewer Supervisor, Teresa Carrasco, Patient Specialist Services Director, Amanda Frost, Chief Operating Officer, Jamie McMahen, Finance Director, and Gretchen Cannon, Chief Financial Officer. Anticipated Completion Date: December 31, 2023.

2022-001

Current Year Findings Corrective Action Plan 2022-001 Improper application of sliding fee discount CFDA Nos. ? 93.224 and 93.527 Federal Award ID # and Year ? 2 H80CS00744-19-00 Program Year 2022 Federal Agency Name: U.S. Department of Health and Human Services Type of finding Significant deficiency in internal control over compliance (recurring) Criteria or Specific Requirement Special Tests and Provisions: Sliding Fee Discounts per Title 42 Chapter 1 Subchapter D Section 51c303(f) Condition The Organization?s sliding fee program provides discounts on patient services based upon the individual?s level of income. However, the Organization applied the incorrect discount based upon the individual?s income per the Organizations sliding fee discount policy. Cause Clerical error in updating and applying the sliding fee category in the billing system for the patient. Effect or Potential Effect Improper sliding fee discounts given to patients. Questioned Costs None Context or Perspective Information A sample of 40 patients were tested out of the total population of 1,994 encounters. The sampling methodology used is not statistically valid. Three patients received the incorrect sliding fee discount based upon their income level. Recommendation We recommend that the Organization implement a verification process to ensure the sliding fee discounts being applied are in accordance with their sliding fee policy. Corrective Action Plan Hidalgo Medical Services will implement a verification process to ensure the sliding fee discounts are applied in accordance with the current sliding fee policy. The Director of Family Support Services will randomly select at least 30% of patients qualified each week to ensure accuracy and all proper documentation is obtained (the new auditing requirement will occur immediately). Additionally, all errors will be corrected immediately. The Director of Family Support Services will report each month to the Chief Support Officer, Chief Financial Officer, and Chief Executive Officers any findings and required correction, if applicable. A comprehensive re-training of current Community Health Workers (CHWs) is to occur by December 2022. A training manual is to be developed, to include competency validation for each CHW, and the new training model will be used for all future CHWs. Person Responsible: Lucy Verdugo, Family Support and Credentialing Director; Donna Sandoval, CHW Administrative Supervisor; and Andrea Montoya, Chief Support Officer Anticipated Completion Date: December 31, 2022.

2021-001

2021-001 Improper application of sliding fee discount CFDA Nos. ? 93.224 and 93.527 Federal Award ID # and Year ? 2 H80CS00744-19-00 Program Year 2021 Federal Agency Name: U.S. Department of Health and Human Services Type of finding Significant deficiency in internal control over compliance Criteria or Specific Requirement Special Tests and Provisions: Sliding Fee Discounts per Title 42 Chapter 1 Subchapter D Section 51c303(f) Condition The Organization?s sliding fee program provides discounts on patient services based upon the individual?s level of income. However, the Organization applied the incorrect discount based upon the individual?s income per the Organizations sliding fee discount policy. Cause Clerical error in updating and applying the sliding fee category in the billing system for the patient. Effect or Potential Effect Improper sliding fee discounts given to patients. Questioned Costs None Context or Perspective Information A sample of 40 patients were tested out of the total population of 2,216 encounters. The sampling methodology used is not and is not intended to be statistically valid. One patient received the incorrect sliding fee discount based upon their income level. Recommendation We recommend that the Organization implement a verification process to ensure the sliding fee discounts being applied are in accordance with their sliding fee policy. Corrective Action Plan Hidalgo Medical Services will implement a verification process to ensure the sliding fee discounts are applied in accordance with the current sliding fee policy. The CHW Administrative Supervisor will randomly select at least 20% of patients qualified each month to ensure accuracy and all proper documentation is obtained. The CHW Administrative Supervisor will report each month to the Chief Support Officer any findings and required correction if applicable. Person Responsible: CHW Administrative Supervisor and Chief Support Officers Anticipated Completion Date: November 30, 2021.

GSA_MIGRATION

2017-002

GSA_MIGRATION

GSA_MIGRATION