establishing and maintaining an fqhc finance office

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


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.

http://bphc.hrsa.gov/about/requirements/hcpreqs.pdf

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.


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


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


Productivity Report

Ensure regular tracking of visits per

provider is monitored at least on a

monthly basis

Lifeline of FQHC

See attached example



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


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.


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.


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

[email protected]

917-359-6725

Compliance/Legal/OSV

Financial-Related Issues

Jeffry Adest, Esq.

Garfunkel Wild, P.C.

[email protected]

(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


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


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.


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.


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.


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


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


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



Questions??

establishing and maintaining an fqhc finance office

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