establishing and maintaining an fqhc finance office
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Establishing and
Maintaining a FQHC
Finance OfficePresenter:
Ira Rothblut, CPA, President of IJR Consulting Corp
Jeffry Adest, Esq., Garfunkel Wild, P.C.
Maria Mazzotta, CPA, CFO of Open Door Family Medical Center
Lennie Trainer, CPA, CGMA, CHFP, CFO of the Joseph p. Addabbo
Family Health Center
OBJECTIVE
Understanding of the complicated
revenue cycles and compliance
requirements.
Recognize best practices in fiscal
management
FQHC Compliance Requirements and
Tips for the OSV
www.ijrconsulting.com 2
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Key Health Center Program
Requirements http://bphc.hrsa.gov/about/requirements/hcpreq
s.pdf
FQHCs deal with these 19 requirements on a
daily basis.
8 of the 19 requirements pertain to
management and finance.
Key to most of these finance areas is to
maintain comprehensive policies and
procedures for financial management and billing
& collections.
Prospective Payment System (PPS)
Base Medicaid rate (2001) based onaverage of 1999 and 2000 cost per visit.
Future Medicaid rates (2002+) based on2001 rate adjusted for MEI and changes inscope of services.
“Wraparound” protection for Medicaidmanaged care contracts.
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Wraparound
Major benefit of being a FQHC
Carefully prepare your MCVR!!!
Internal preparation of quarterly MCVR’s an
excellent strategy
Prepare a rate x visits analysis each month
Bill the 4028’s
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Indigent Care Pool
Old Methodology
New Methodology
How this may change your future revenue
streams
Preparation of AHCF – what you should
double and triple check
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Productivity Report
Ensure regular tracking of visits per
provider is monitored at least on a
monthly basis
Lifeline of FQHC
See attached example
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Fiscal Responsibilities
- Cash Management (weekly projection of disbursementsand receipts)
- Presentations to the Board, including monthly internalfinancial statements.
- Monthly/Quarterly financial statements by site anddepartment.
- Operating budget
- Capital budget
- Creation and timely update of Accounting and BillingPolicies and Procedures Manuals.
- Credentialing
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Fiscal Department Deliverables
Overarching Responsibilities
- Growth analysis and strategic planning.
- Preparation of Federal, state and city reporting.
- HRSA reporting and compliance.
- Cash projections and management.
- Supervision of Billing and collections.
- Supervision of payroll.
- Accounts Payable management.
- Creation and timely update of Accounting and BillingPolicies and Procedures Manuals.
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Fiscal Department Deliverables
Tasks and Reports
- Presentations to the Board, includingmonthly internal financial statements.
- Budgeting for Federal grants and statecontracts.
- Monthly/quarterly vouchering of state andlocal contracts.
- Contract Accruals management.
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Fiscal Department DeliverablesTasks and Reports
- Collection rate/remediation of collection issues
- Net revenue per visit
- Days in accounts receivable
- Reconciliation of general ledger to accountsreceivable subsidiary ledger
- Members and visits by managed care plan
- Provider productivity
- Exam room productivity
- Total Cost per Patient
- Medical Cost per Medical Encounter
- Grant Dollars per Patient
Ira J Rothblut, CPA
irothblut@ijrconsulting.com
917-359-6725
Compliance/Legal/OSV
Financial-Related Issues
Jeffry Adest, Esq.
Garfunkel Wild, P.C.
jadest@garfunkelwild.com
(516) 393-2270/(201) 883-1030
4063277 15 © 2016 Garfunkel Wild, P.C.
Overview
FQHC Compliance Requirements and Tips
OSV Preparation
HRSA Draft Compliance Manual
OMIG General Requirements
4063277 16 © 2016 Garfunkel Wild, P.C.
FQHC/OSV Compliance – Sliding Fee
Discounts Requirements Health center has system in place to determine eligibility for patient discounts
adjusted on basis of patient’s ability to pay:
The Center must provide a full discount (other than nominal fees) to
individuals and families with annual incomes at or below 100% of the
Federal poverty level (the “FPL”)
Fees in accordance with a sliding discount policy based on family size and
income (with at least three different categories) must be charged to those
with incomes between 100% and 200% of the FPL
With limited exceptions, no discounts may be provided to patients with
incomes over 200% of the FPL
All required and additional services within a health center’s approved scope of
project are available to patients regardless of ability to pay through the sliding
fee discount program
4063277 17 © 2016 Garfunkel Wild, P.C.
FQHC/OSV Compliance – Sliding Fee
Discounts Requirements
The Sliding Fee Discount Program must
including establishing the following:
A schedule of fees for services (revised annually to
reflect updates to the FPL);
A corresponding schedule of discounts for eligible
patients that is adjusted based on the patient’s ability
to pay; and
Governing board-approved policies and the
organization’s supporting operating procedures,
including those around billing and collections.
4063277 18 © 2016 Garfunkel Wild, P.C.
Sliding Fee: FQHC/OSV Compliance Tips
Health centers must have a governing board-approved policy that is reviewed/revised annually
The policy must apply to both uninsured and insured patients who qualify based on income and family size
There are special rules for patients above 200% of the FPL
Patients should be made aware of the Sliding Fee Scale Discounts, for example: Post signs in the lobby, receptionists’ desks and each treatment room;
Post information on the health center’s website;
Inform patients in person and/or at the time of new patient phone calls
For services the health center provides only via a formal referral
arrangement, the health center must ensure that the referral
provider’s discounts meet the SFDS criteria.
FQHC/OSV Compliance – Billing &
Collections Requirements
Health centers must make reasonable efforts to
secure payment from patients for services, while
ensuring that no patient is denied services based
on inability to pay.
Health centers must establish policies and
procedures for waiving charges under certain,
specified circumstances.
4063277 19 © 2016 Garfunkel Wild, P.C.
Billing & Collections:
FQHC/OSV Compliance Tips
Health centers are required to seek
reimbursement from patients
Policies must match actual practices
Policies should include:
Provisions for waiving charges
Payment incentives (if applicable)
Refusal to pay
Wrap billing
4028 billing4063277 20 © 2016 Garfunkel Wild, P.C.
FQHC/OSV Compliance - Financial
Management & Accounting Requirements
Health center maintains accounting and internal control systems, which Are appropriate to the size and complexity of the organization
Reflect GAAP
Separate functions appropriate to organizational size to safeguard assets and maintain financial stability
Health center assures an annual independent financial audit is performed in accordance with Federal audit requirements, including submission of a corrective action plan addressing: all findings,
questioned costs,
reportable conditions, and
material weaknesses cited in the Audit Report.
4063277 21 © 2016 Garfunkel Wild, P.C.
Financial Management &
Accounting: FQHC/OSV Tips Policies must match operational activities
Financial management and accounting activities must
be reported to the Board
Health center should ensure that governing Board
approves audit
Health center must set financial targets and measure
achievement
Must have internal control systems for cash
Health center must trend productivity and create
reports regularly4063277 22 © 2016 Garfunkel Wild, P.C.
FQHC/OSV Compliance – Budget
Requirements
Health centers must develop a budget that
reflects the costs of the operations, expenses
and revenues (including the federal grant)
necessary to accomplish the service delivery
plan, including the number of patients to be
served
4063277 23 © 2016 Garfunkel Wild, P.C.
Budget: FQHC/OSV Tips
Board must review and approve the annual
budget
Health center must regularly report to the Board
about financial activities
Monthly and year to date comparisons of actual vs.
budgeted revenues and expenses and comparisons to
prior year
Use of charts/diagrams
Financial ratios
Comparison to other FQHCs4063277 24 © 2016 Garfunkel Wild, P.C.
Office of the Medicaid Inspector
General Requirements• Pursuant to NY Law, FQHCs are required by
law and regulation to establish and maintain an
effective compliance program.
• FQHCs must annually certify that they have an
effective compliance program (on or before
December 31st)
• OMIG can do periodic audits
4063277 25 © 2016 Garfunkel Wild, P.C.
8 Required Elements for
an Effective Compliance ProgramThere are 8 elements that are required under New York State Law. They include:
Written Policies and Procedures
Designation of Compliance Officer
Training and Education
Communication lines to the Compliance Officer
Disciplinary Policies
Identification of Compliance Risk Areas and noncompliance
Responding to Compliance Issues
Policy of Non-Intimidation and Non-Retaliation
4063277 26 © 2016 Garfunkel Wild, P.C.
4063277 27 © 2016 Garfunkel Wild, P.C.
Questions??
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