Audit 26659

Finding 2022-001 Eligibility Identification of the Federal Program: Grantor: Department of Health and Human Services Pass-Through Entity: Public Health Solutions (MHRA) Program Name: HIV Emergency Relief Project Grants Assistance Listing No.: 93.914 Criteria or Specific Requirement: The Uniform Guidance 2 CFR section 200.303 states, ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? The Addendum 1, Client Eligibility Addendum of the award grant agreement states the following: ?Subrecipients must obtain evidence of household income for all new and continuing clients to establish eligibility for this program during pre-enrollment, enrollment or re-assessment activities. Clients who do not meet the income requirements are not eligible for this program and should be referred to another program within the organization that is not funded by RW Part A. ?Clients must be re-assessed for income eligibility at least every six months, at the time of the scheduled re-assessment. If, at the time of re-assessment, there is a change in household income and the household income exceeds the eligibility threshold, program staff must obtain documentation of the new household income before services are discontinued. If, at the time of re-assessment, there is no change in household income, or there is a change but it does not exceed the eligibility threshold, the client must sign an attestation stating there is no change in eligibility. This attestation is filed in the client record. Subrecipients must conduct an annual reassessment of income eligibility, using the updated Federal Poverty Guidelines, and must obtain and file documentation of income for each client in order for the client to remain enrolled. ?Clients must confirm residency at least every six months, at the time of the scheduled re-assessment. If at the time of re-assessment there is a change in residency, the provider must obtain documentation of the new address. If at the time of re-assessment there is no change in residency the client must sign an attestation stating there is no change. This attestation is filed in the client record. Subrecipient must request and obtain current documentation of residency annually. The Addendum 1, Client Eligibility Addendum of the award grant agreement states the following, effective March 1, 2022: ?Subrecipients must obtain evidence of household income for all new enrolled clients to comply with income criteria eligibility for this program. Clients who do not meet the income criteria requirements are not eligible for this program and should be referred to another program within the organization that is not funded by Ryan White Part A. ?Subrecipients must conduct an annual reassessment of income eligibility using the updated Federal Poverty Guidelines. Clients must be re-assessed for income eligibility at least once per program year after initial verification occurs (within 90 days of program enrollment). This may include during any Reassessment. If, at the time of re-assessment, there is a change in household income and the household income exceeds the eligibility threshold, program staff must obtain documentation of the new household income before services are discontinued. If, at the time of re-assessment, there is no change in household income, or there is a change, but it does not exceed the eligibility income threshold, the subrecipient can obtain a signed client-attestation and document in the client record. ?Clients must be re-assessed for residency criteria eligibility at least once per program year after initial verification occurs (within 90 days of program enrollment). This may include during any Reassessment. If at the time of re-assessment there is a change in residency, the subrecipient must obtain documentation of the new address and update the Common Demographics form in eSHARE. Condition: During our testing of the internal controls over the eligibility compliance requirement, we observed management did not have effective internal controls in place to retain supporting documentation to support management?s reassessment of a participant?s continued eligibility to receive program services. Cause: Management did not have effective internal controls in place over the compliance requirements as stated in the criteria or specific requirement section above. Effect or Potential Effect: Participants receiving services from this grant could potentially be ineligible to receive program services. Questioned Costs: Questioned costs for Assistance Listing No. 93.914 are indeterminable, as program expenditures are not made on a per participant basis. Context: During our testing of internal controls over eligibility as it relates to intake eligibility determination, we selected a sample of 19 out of a total population of 182. We observed that management did not retain the required supporting documentation for 1 participant to support management?s verification of income criteria necessary to support the participant?s eligibility to receive program services. During our testing of internal controls over eligibility as it relates to the reassessment of eligibility, we selected a sample of 40 out of a total population of 339. We observed that management did not retain the required supporting documentation for 15 participants to support management?s reassessment of the participants? continued eligibility to receive program services. Identification as a repeat finding, if applicable: No. Recommendation: We recommend that management implement effective internal controls to retain supporting documentation to support income verification and to perform the reassessment of participants and properly have supporting documentation for each participant in the program to support their eligibility to receive program services. Views of Responsible Officials: Management acknowledges this finding and will address remediation in the accompanying corrective action plan.

Finding 2022-001 Eligibility Identification of the Federal Program: Grantor: Department of Health and Human Services Pass-Through Entity: Public Health Solutions (MHRA) Program Name: HIV Emergency Relief Project Grants Assistance Listing No.: 93.914 Criteria or Specific Requirement: The Uniform Guidance 2 CFR section 200.303 states, ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? The Addendum 1, Client Eligibility Addendum of the award grant agreement states the following: ?Subrecipients must obtain evidence of household income for all new and continuing clients to establish eligibility for this program during pre-enrollment, enrollment or re-assessment activities. Clients who do not meet the income requirements are not eligible for this program and should be referred to another program within the organization that is not funded by RW Part A. ?Clients must be re-assessed for income eligibility at least every six months, at the time of the scheduled re-assessment. If, at the time of re-assessment, there is a change in household income and the household income exceeds the eligibility threshold, program staff must obtain documentation of the new household income before services are discontinued. If, at the time of re-assessment, there is no change in household income, or there is a change but it does not exceed the eligibility threshold, the client must sign an attestation stating there is no change in eligibility. This attestation is filed in the client record. Subrecipients must conduct an annual reassessment of income eligibility, using the updated Federal Poverty Guidelines, and must obtain and file documentation of income for each client in order for the client to remain enrolled. ?Clients must confirm residency at least every six months, at the time of the scheduled re-assessment. If at the time of re-assessment there is a change in residency, the provider must obtain documentation of the new address. If at the time of re-assessment there is no change in residency the client must sign an attestation stating there is no change. This attestation is filed in the client record. Subrecipient must request and obtain current documentation of residency annually. The Addendum 1, Client Eligibility Addendum of the award grant agreement states the following, effective March 1, 2022: ?Subrecipients must obtain evidence of household income for all new enrolled clients to comply with income criteria eligibility for this program. Clients who do not meet the income criteria requirements are not eligible for this program and should be referred to another program within the organization that is not funded by Ryan White Part A. ?Subrecipients must conduct an annual reassessment of income eligibility using the updated Federal Poverty Guidelines. Clients must be re-assessed for income eligibility at least once per program year after initial verification occurs (within 90 days of program enrollment). This may include during any Reassessment. If, at the time of re-assessment, there is a change in household income and the household income exceeds the eligibility threshold, program staff must obtain documentation of the new household income before services are discontinued. If, at the time of re-assessment, there is no change in household income, or there is a change, but it does not exceed the eligibility income threshold, the subrecipient can obtain a signed client-attestation and document in the client record. ?Clients must be re-assessed for residency criteria eligibility at least once per program year after initial verification occurs (within 90 days of program enrollment). This may include during any Reassessment. If at the time of re-assessment there is a change in residency, the subrecipient must obtain documentation of the new address and update the Common Demographics form in eSHARE. Condition: During our testing of the internal controls over the eligibility compliance requirement, we observed management did not have effective internal controls in place to retain supporting documentation to support management?s reassessment of a participant?s continued eligibility to receive program services. Cause: Management did not have effective internal controls in place over the compliance requirements as stated in the criteria or specific requirement section above. Effect or Potential Effect: Participants receiving services from this grant could potentially be ineligible to receive program services. Questioned Costs: Questioned costs for Assistance Listing No. 93.914 are indeterminable, as program expenditures are not made on a per participant basis. Context: During our testing of internal controls over eligibility as it relates to intake eligibility determination, we selected a sample of 19 out of a total population of 182. We observed that management did not retain the required supporting documentation for 1 participant to support management?s verification of income criteria necessary to support the participant?s eligibility to receive program services. During our testing of internal controls over eligibility as it relates to the reassessment of eligibility, we selected a sample of 40 out of a total population of 339. We observed that management did not retain the required supporting documentation for 15 participants to support management?s reassessment of the participants? continued eligibility to receive program services. Identification as a repeat finding, if applicable: No. Recommendation: We recommend that management implement effective internal controls to retain supporting documentation to support income verification and to perform the reassessment of participants and properly have supporting documentation for each participant in the program to support their eligibility to receive program services. Views of Responsible Officials: Management acknowledges this finding and will address remediation in the accompanying corrective action plan.

Finding 2022-001 Eligibility Identification of the Federal Program: Grantor: Department of Health and Human Services Pass-Through Entity: Public Health Solutions (MHRA) Program Name: HIV Emergency Relief Project Grants Assistance Listing No.: 93.914 Criteria or Specific Requirement: The Uniform Guidance 2 CFR section 200.303 states, ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? The Addendum 1, Client Eligibility Addendum of the award grant agreement states the following: ?Subrecipients must obtain evidence of household income for all new and continuing clients to establish eligibility for this program during pre-enrollment, enrollment or re-assessment activities. Clients who do not meet the income requirements are not eligible for this program and should be referred to another program within the organization that is not funded by RW Part A. ?Clients must be re-assessed for income eligibility at least every six months, at the time of the scheduled re-assessment. If, at the time of re-assessment, there is a change in household income and the household income exceeds the eligibility threshold, program staff must obtain documentation of the new household income before services are discontinued. If, at the time of re-assessment, there is no change in household income, or there is a change but it does not exceed the eligibility threshold, the client must sign an attestation stating there is no change in eligibility. This attestation is filed in the client record. Subrecipients must conduct an annual reassessment of income eligibility, using the updated Federal Poverty Guidelines, and must obtain and file documentation of income for each client in order for the client to remain enrolled. ?Clients must confirm residency at least every six months, at the time of the scheduled re-assessment. If at the time of re-assessment there is a change in residency, the provider must obtain documentation of the new address. If at the time of re-assessment there is no change in residency the client must sign an attestation stating there is no change. This attestation is filed in the client record. Subrecipient must request and obtain current documentation of residency annually. The Addendum 1, Client Eligibility Addendum of the award grant agreement states the following, effective March 1, 2022: ?Subrecipients must obtain evidence of household income for all new enrolled clients to comply with income criteria eligibility for this program. Clients who do not meet the income criteria requirements are not eligible for this program and should be referred to another program within the organization that is not funded by Ryan White Part A. ?Subrecipients must conduct an annual reassessment of income eligibility using the updated Federal Poverty Guidelines. Clients must be re-assessed for income eligibility at least once per program year after initial verification occurs (within 90 days of program enrollment). This may include during any Reassessment. If, at the time of re-assessment, there is a change in household income and the household income exceeds the eligibility threshold, program staff must obtain documentation of the new household income before services are discontinued. If, at the time of re-assessment, there is no change in household income, or there is a change, but it does not exceed the eligibility income threshold, the subrecipient can obtain a signed client-attestation and document in the client record. ?Clients must be re-assessed for residency criteria eligibility at least once per program year after initial verification occurs (within 90 days of program enrollment). This may include during any Reassessment. If at the time of re-assessment there is a change in residency, the subrecipient must obtain documentation of the new address and update the Common Demographics form in eSHARE. Condition: During our testing of the internal controls over the eligibility compliance requirement, we observed management did not have effective internal controls in place to retain supporting documentation to support management?s reassessment of a participant?s continued eligibility to receive program services. Cause: Management did not have effective internal controls in place over the compliance requirements as stated in the criteria or specific requirement section above. Effect or Potential Effect: Participants receiving services from this grant could potentially be ineligible to receive program services. Questioned Costs: Questioned costs for Assistance Listing No. 93.914 are indeterminable, as program expenditures are not made on a per participant basis. Context: During our testing of internal controls over eligibility as it relates to intake eligibility determination, we selected a sample of 19 out of a total population of 182. We observed that management did not retain the required supporting documentation for 1 participant to support management?s verification of income criteria necessary to support the participant?s eligibility to receive program services. During our testing of internal controls over eligibility as it relates to the reassessment of eligibility, we selected a sample of 40 out of a total population of 339. We observed that management did not retain the required supporting documentation for 15 participants to support management?s reassessment of the participants? continued eligibility to receive program services. Identification as a repeat finding, if applicable: No. Recommendation: We recommend that management implement effective internal controls to retain supporting documentation to support income verification and to perform the reassessment of participants and properly have supporting documentation for each participant in the program to support their eligibility to receive program services. Views of Responsible Officials: Management acknowledges this finding and will address remediation in the accompanying corrective action plan.

Finding 2022-001 Eligibility Identification of the Federal Program: Grantor: Department of Health and Human Services Pass-Through Entity: Public Health Solutions (MHRA) Program Name: HIV Emergency Relief Project Grants Assistance Listing No.: 93.914 Criteria or Specific Requirement: The Uniform Guidance 2 CFR section 200.303 states, ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? The Addendum 1, Client Eligibility Addendum of the award grant agreement states the following: ?Subrecipients must obtain evidence of household income for all new and continuing clients to establish eligibility for this program during pre-enrollment, enrollment or re-assessment activities. Clients who do not meet the income requirements are not eligible for this program and should be referred to another program within the organization that is not funded by RW Part A. ?Clients must be re-assessed for income eligibility at least every six months, at the time of the scheduled re-assessment. If, at the time of re-assessment, there is a change in household income and the household income exceeds the eligibility threshold, program staff must obtain documentation of the new household income before services are discontinued. If, at the time of re-assessment, there is no change in household income, or there is a change but it does not exceed the eligibility threshold, the client must sign an attestation stating there is no change in eligibility. This attestation is filed in the client record. Subrecipients must conduct an annual reassessment of income eligibility, using the updated Federal Poverty Guidelines, and must obtain and file documentation of income for each client in order for the client to remain enrolled. ?Clients must confirm residency at least every six months, at the time of the scheduled re-assessment. If at the time of re-assessment there is a change in residency, the provider must obtain documentation of the new address. If at the time of re-assessment there is no change in residency the client must sign an attestation stating there is no change. This attestation is filed in the client record. Subrecipient must request and obtain current documentation of residency annually. The Addendum 1, Client Eligibility Addendum of the award grant agreement states the following, effective March 1, 2022: ?Subrecipients must obtain evidence of household income for all new enrolled clients to comply with income criteria eligibility for this program. Clients who do not meet the income criteria requirements are not eligible for this program and should be referred to another program within the organization that is not funded by Ryan White Part A. ?Subrecipients must conduct an annual reassessment of income eligibility using the updated Federal Poverty Guidelines. Clients must be re-assessed for income eligibility at least once per program year after initial verification occurs (within 90 days of program enrollment). This may include during any Reassessment. If, at the time of re-assessment, there is a change in household income and the household income exceeds the eligibility threshold, program staff must obtain documentation of the new household income before services are discontinued. If, at the time of re-assessment, there is no change in household income, or there is a change, but it does not exceed the eligibility income threshold, the subrecipient can obtain a signed client-attestation and document in the client record. ?Clients must be re-assessed for residency criteria eligibility at least once per program year after initial verification occurs (within 90 days of program enrollment). This may include during any Reassessment. If at the time of re-assessment there is a change in residency, the subrecipient must obtain documentation of the new address and update the Common Demographics form in eSHARE. Condition: During our testing of the internal controls over the eligibility compliance requirement, we observed management did not have effective internal controls in place to retain supporting documentation to support management?s reassessment of a participant?s continued eligibility to receive program services. Cause: Management did not have effective internal controls in place over the compliance requirements as stated in the criteria or specific requirement section above. Effect or Potential Effect: Participants receiving services from this grant could potentially be ineligible to receive program services. Questioned Costs: Questioned costs for Assistance Listing No. 93.914 are indeterminable, as program expenditures are not made on a per participant basis. Context: During our testing of internal controls over eligibility as it relates to intake eligibility determination, we selected a sample of 19 out of a total population of 182. We observed that management did not retain the required supporting documentation for 1 participant to support management?s verification of income criteria necessary to support the participant?s eligibility to receive program services. During our testing of internal controls over eligibility as it relates to the reassessment of eligibility, we selected a sample of 40 out of a total population of 339. We observed that management did not retain the required supporting documentation for 15 participants to support management?s reassessment of the participants? continued eligibility to receive program services. Identification as a repeat finding, if applicable: No. Recommendation: We recommend that management implement effective internal controls to retain supporting documentation to support income verification and to perform the reassessment of participants and properly have supporting documentation for each participant in the program to support their eligibility to receive program services. Views of Responsible Officials: Management acknowledges this finding and will address remediation in the accompanying corrective action plan.