Criteria: Under 2 CFR 200.320(c) vendors above a micro-purchase threshold require a competitive process that includes soliciting multiple bids/quotes to justify best value. The Uniform Guidance requires purchasing decisions to be documented, including sole source justification, as applicable.
Condition: For two out of five procurement selections totaling $158,000, evidence of the procurement process (signed competitive bid or sole source documentation and the related approvals), was not retained in the procurement file. As such, we were unable to obtain the required documentation to support vendor selection and price justification.
Cause: The buyers executing these transactions did not obtain and maintain the required documentation evidencing that these transactions were conducted in accordance with federal requirements.
Effect: Failure to obtain and maintain complete procurement files may lead to non-compliance with required regulations.
Questioned Costs: There are no questioned costs associated with this finding as procurements were made for allowable transactions.
Recommendation: We recommend Management enhance their existing policies and procedures to ensure documentation is retained to justify the rationale for purchasing decisions consistent with the Uniform Guidance. This could include additional training in this area and providing readily available guidance as to what documentation is required prior to executing federal purchasing transactions. Additionally, we recommend that Management retroactively document vendor and price rationale for the two selections and retain this documentation within the procurement file.
Criteria: Under 2 CFR 200.320(c) vendors above a micro-purchase threshold require a competitive process that includes soliciting multiple bids/quotes to justify best value. The Uniform Guidance requires purchasing decisions to be documented, including sole source justification, as applicable.
Condition: For two out of five procurement selections totaling $158,000, evidence of the procurement process (signed competitive bid or sole source documentation and the related approvals), was not retained in the procurement file. As such, we were unable to obtain the required documentation to support vendor selection and price justification.
Cause: The buyers executing these transactions did not obtain and maintain the required documentation evidencing that these transactions were conducted in accordance with federal requirements.
Effect: Failure to obtain and maintain complete procurement files may lead to non-compliance with required regulations.
Questioned Costs: There are no questioned costs associated with this finding as procurements were made for allowable transactions.
Recommendation: We recommend Management enhance their existing policies and procedures to ensure documentation is retained to justify the rationale for purchasing decisions consistent with the Uniform Guidance. This could include additional training in this area and providing readily available guidance as to what documentation is required prior to executing federal purchasing transactions. Additionally, we recommend that Management retroactively document vendor and price rationale for the two selections and retain this documentation within the procurement file.
Criteria: Per the AACO/PA Dept. of Health Ryan White Part A/B – Payer of Last Resort Client Certification Form Instructions, “The Health Resources and Services Administration (HRSA) standards require service providers who receive Ryan White funding to screen clients and collect supporting documentation to certify their eligibility for Ryan White-funded services based on HIV positive diagnosis, identity, residence, insurance status, and income. The standards further require Ryan White recipients and subrecipients to “conduct timely eligibility confirmations, in accordance with their policies and procedures, to assess if the client’s income and/or residency status has changed.” Additionally, the form states that copy of all documentation are to be retained by the provider.
The City of Philadelphia Subrecipient Audit Guide Section 6130.04 provides a list of documents to be maintained and states “case management service providers are required to keep a file on each client
served.” Further, per the Universal Monitoring Standards set forth by HRSA, the Ryan White HIV/AIDS Program Part A and B Monitoring Standards require service providers who receive Ryan White funding to screen to certify eligibility for Ryan White-funded services. The guidance states that documentation of eligibility determination is required in client records, as evidenced by copies of documents.
Condition: For 2 of the 25 patient files selected for testing, while there was initial intake documentation in the file to support the eligibility of the patient, the required recertification had not been performed timely. However, for both program participants, CHOP provided records to support that the program participant met the eligibility requirements.
Cause: Both patients were originally certified as eligible based on the Ryan White criteria noted above. However, at subsequent patient visits, grant staff did not check for changes in status that could deem the patients as ineligible. For both patients, recertification did not occur for a period greater than one year from initial certification (patients were last certified in April 2023).
Effect: Changes in patients’ eligibility residence status could be overlooked and services could be provided to ineligible patients.
Questioned Costs: There were no questioned costs related to this finding, as the patients were eligible to receive care under this grant per the patient eligibility requirements.
Recommendation: We recommend that Management formalize its policy for recertification of patient eligibility and that Management ensures all grant staff are made aware of, and adhere to, the policy requirements. We recommend the recertification process occurs on an annual basis, at minimum, and proper documentation of certification is retained within the file to evidence the patient’s continued eligibility.
Criteria: Under 2 CFR 200.320(c) vendors above a micro-purchase threshold require a competitive process that includes soliciting multiple bids/quotes to justify best value. The Uniform Guidance requires purchasing decisions to be documented, including sole source justification, as applicable.
Condition: For two out of five procurement selections totaling $158,000, evidence of the procurement process (signed competitive bid or sole source documentation and the related approvals), was not retained in the procurement file. As such, we were unable to obtain the required documentation to support vendor selection and price justification.
Cause: The buyers executing these transactions did not obtain and maintain the required documentation evidencing that these transactions were conducted in accordance with federal requirements.
Effect: Failure to obtain and maintain complete procurement files may lead to non-compliance with required regulations.
Questioned Costs: There are no questioned costs associated with this finding as procurements were made for allowable transactions.
Recommendation: We recommend Management enhance their existing policies and procedures to ensure documentation is retained to justify the rationale for purchasing decisions consistent with the Uniform Guidance. This could include additional training in this area and providing readily available guidance as to what documentation is required prior to executing federal purchasing transactions. Additionally, we recommend that Management retroactively document vendor and price rationale for the two selections and retain this documentation within the procurement file.
Criteria: Under 2 CFR 200.320(c) vendors above a micro-purchase threshold require a competitive process that includes soliciting multiple bids/quotes to justify best value. The Uniform Guidance requires purchasing decisions to be documented, including sole source justification, as applicable.
Condition: For two out of five procurement selections totaling $158,000, evidence of the procurement process (signed competitive bid or sole source documentation and the related approvals), was not retained in the procurement file. As such, we were unable to obtain the required documentation to support vendor selection and price justification.
Cause: The buyers executing these transactions did not obtain and maintain the required documentation evidencing that these transactions were conducted in accordance with federal requirements.
Effect: Failure to obtain and maintain complete procurement files may lead to non-compliance with required regulations.
Questioned Costs: There are no questioned costs associated with this finding as procurements were made for allowable transactions.
Recommendation: We recommend Management enhance their existing policies and procedures to ensure documentation is retained to justify the rationale for purchasing decisions consistent with the Uniform Guidance. This could include additional training in this area and providing readily available guidance as to what documentation is required prior to executing federal purchasing transactions. Additionally, we recommend that Management retroactively document vendor and price rationale for the two selections and retain this documentation within the procurement file.
Criteria: Per the AACO/PA Dept. of Health Ryan White Part A/B – Payer of Last Resort Client Certification Form Instructions, “The Health Resources and Services Administration (HRSA) standards require service providers who receive Ryan White funding to screen clients and collect supporting documentation to certify their eligibility for Ryan White-funded services based on HIV positive diagnosis, identity, residence, insurance status, and income. The standards further require Ryan White recipients and subrecipients to “conduct timely eligibility confirmations, in accordance with their policies and procedures, to assess if the client’s income and/or residency status has changed.” Additionally, the form states that copy of all documentation are to be retained by the provider.
The City of Philadelphia Subrecipient Audit Guide Section 6130.04 provides a list of documents to be maintained and states “case management service providers are required to keep a file on each client
served.” Further, per the Universal Monitoring Standards set forth by HRSA, the Ryan White HIV/AIDS Program Part A and B Monitoring Standards require service providers who receive Ryan White funding to screen to certify eligibility for Ryan White-funded services. The guidance states that documentation of eligibility determination is required in client records, as evidenced by copies of documents.
Condition: For 2 of the 25 patient files selected for testing, while there was initial intake documentation in the file to support the eligibility of the patient, the required recertification had not been performed timely. However, for both program participants, CHOP provided records to support that the program participant met the eligibility requirements.
Cause: Both patients were originally certified as eligible based on the Ryan White criteria noted above. However, at subsequent patient visits, grant staff did not check for changes in status that could deem the patients as ineligible. For both patients, recertification did not occur for a period greater than one year from initial certification (patients were last certified in April 2023).
Effect: Changes in patients’ eligibility residence status could be overlooked and services could be provided to ineligible patients.
Questioned Costs: There were no questioned costs related to this finding, as the patients were eligible to receive care under this grant per the patient eligibility requirements.
Recommendation: We recommend that Management formalize its policy for recertification of patient eligibility and that Management ensures all grant staff are made aware of, and adhere to, the policy requirements. We recommend the recertification process occurs on an annual basis, at minimum, and proper documentation of certification is retained within the file to evidence the patient’s continued eligibility.