Elixir Audits, Chartered Accountants

A hospital's largest asset is usually a receivable from the National Health Insurance Scheme, and its largest risk is that a portion of that receivable will be rejected for reasons decided at the point of care months earlier.

Claims are won or lost at the bedside

A claim is rejected because documentation was incomplete, coding was wrong, or authorisation was not obtained, and all three happen in the clinical area rather than in finance. By the time finance sees the rejection the episode is months old and the supporting record is difficult to reconstruct. The control that matters is at capture, not at submission.

Ageing tells you what the provision should be

Claims receivable should be aged by submission date and analysed by rejection reason, so that the provision is derived from your own experience rather than from a percentage somebody chose. Where a hospital cannot say which claim types get rejected and why, the provision is a guess and the auditor will treat it as one.

The tax question nobody asks

Healthcare providers typically make a mix of exempt and taxable supplies, and where that mix exists input tax has to be apportioned. Pharmacy sales, private patient work, diagnostics for external referrals and non-clinical services all sit differently. We rarely find this apportionment done properly, and the direction of the error is usually in the Ghana Revenue Authority's favour.

Consultants

Visiting consultants engaged on a fee basis raise a genuine employment status question, and the answer determines whether PAYE should have been operated. Where a consultant works substantially exclusively at one facility on set sessions, the arrangement is worth examining before somebody else examines it.

At capture

Where claims are won or lost, not at submission

By rejection reason

How the provision should actually be derived

Apportionment

Input tax, where exempt and taxable supplies mix

Findings

What we find in healthcare providers

Concentrated in the claims cycle and in two tax questions that are rarely asked until an officer asks them.

The number to ask forRejection rate by claim type over the last twelve months. If nobody can produce it, the receivable provision is not derived from evidence and the claims process cannot be improved, because nobody knows where it fails.

What we find most often

  • Claims receivable aged by submission date only, with no analysis by rejection reason
  • Provision set as a flat percentage rather than derived from actual rejection experience
  • Rejected claims not resubmitted within the permitted window
  • Input tax not apportioned between exempt and taxable supplies
  • Consultant engagement status unexamined where the arrangement looks like employment
  • Pharmacy stock counted infrequently, with expiry losses absorbed rather than analysed
  • Clinical procurement outside normal approval limits because it is clinical
  • Equipment leases and service contracts not assessed under IFRS 16

Questions

Questions from healthcare providers

How should NHIS claims receivable be provided against?
From your own rejection experience, analysed by claim type and by age from submission, rather than from a flat percentage. If you cannot say which claim types get rejected and why, the provision is a guess, and it is also impossible to improve the process because nobody knows where it fails.
Why do our claims get rejected?
Almost always for documentation, coding or authorisation, and all three are decided in the clinical area at the point of care rather than in finance. The effective control is at capture. By the time finance sees a rejection the episode is months old and the record is hard to reconstruct.
Do we need to apportion input tax?
If you make both exempt and taxable supplies, yes. Most providers do: pharmacy sales, private patient work and diagnostics for external referrals sit differently from core exempt services. We rarely find this done properly, and the error is usually in the Ghana Revenue Authority's favour rather than yours.
Are our consultants employees for tax purposes?
It depends on the substance of the arrangement rather than on the label in the contract. Where a consultant works substantially exclusively at one facility on set sessions, the arrangement is worth examining before an officer examines it, because the PAYE consequence accumulates monthly.

Next step

Send us your claims ageing and your rejection analysis.

If the second does not exist, that is the finding, and producing it is usually the highest-return piece of work available to a hospital.

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