Federal Program Information Federal Agencies: Department of Health and Human Services (“HHS”) Pass-Through Entity: Virginia Department of Health Pass-Through Entity Number: INORWB611-GY23; INORWB611-GY24 Awards: Assistance Listing Number 93.917 – HIV Emergency Relief Project Grants (Part B) Award Periods: April 1, 2023 to March 31, 2024; April 1, 2024 to March 31, 2025 Description: Timely Completion of the 24-month Eligibility Screening Criteria In accordance with Title 2 U.S. Code of Federal Regulations, Part 200.303, Internal controls, “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.” Per the terms and conditions of the pass-through entity agreement between the Virginia Department of Health (the Department) and the Inova Juniper Program (IJP), IJP is required to “conduct and complete a full RWHAP B eligibility screening for all clients for any allowable Ryan White services prior to enrollment in the RWHAP B program and every 24-months thereafter by following the procedure from the department” (INORWB611 – Scope of Services – Section G1). The procedure from the Department of the award requires the recipient to resubmit documents for residency, household income and proof of insurance before the 24-month eligibility period ends. Condition IHS did not have appropriately designed internal controls in place to ensure that the documentation is obtained and reviewed to verify eligibility prior to the end of the 24-month period. Cause IJP has policies and procedures in place to obtain the eligibility documents from all clients and retain in their files. IJP’s policies and procedures specify that an eligibility worker will meet with each client for an initial screening to verify residency, income, insurance status, and HIV status. The eligibility worker is required to meet with the client to update the required eligibility screening and include the required documentation in the client file by the 24-month period end. Additionally, an eligibility worker is required to periodically make inquiries of the patient as to any changes of income, address, or insurance coverage. If any changes are noted, submission of proper documentation is required. If the eligibility workers do not have access to the proper reassessment requirement date, the required documentation may not be obtained by the 24 month period end. Effect or potential effect Eligibility workers did not timely obtain the required documentation related to the 24-month eligibility screening for certain clients before the required date. Based on the terms and conditions of the pass-through agreement with the Department, the clients whose eligibility was not completed by the deadline would not be considered eligible and should be discharged from the program. Questioned costs Indeterminable Costs are not tracked by client. Identification of a repeat finding This is a repeat finding and relates to prior year finding 2023-001. Context During our audit, we selected a sample of 60 clients for testing and noted that the 24-month eligibility screening was submitted to the Department after the eligibility expiration date for 5 clients. We further evaluated the 5 clients and noted that either no services were performed prior to obtaining full eligibility screening or if services were provided, the services were fully covered by insurance. Recommendation Management should continue to implement procedures to ensure completion of the eligibility screening prior to the end of the 24-month eligibility period including steps to ensure the eligibility date aligns with the supporting documentation. View of responsible officials Management concurs with the finding and will continue to implement further procedures to ensure that timely documentation is received with regard to eligibility.
Federal Program Information Federal Agencies: Department of Health and Human Services (“HHS”) Pass-Through Entity: Virginia Department of Health; Not Applicable Pass-Through Entity Number: INORWB611-GY23; INORWB611-GY24; Not Applicable Awards: Assistance Listing 93.917 – HIV Emergency Relief Project Grants; Assistance Listing 93.918 – Grants to Provide Outpatient Early Intervention Services with Respect to HIV Disease Award Periods: April 1, 2023 to March 31, 2024; April 1, 2024 to March 31, 2025; May 1, 2023 to April 30, 2024; May 1, 2024 to April 30, 2025 Description: Timely Application of Program Income Prior to Requesting Additional Cash Payments Criteria In accordance with Title 2 U.S. Code of Federal Regulations, Part 200.303, Internal controls, “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.” Per the terms and conditions of the notice of award (Assistance Listing 93.918) and the pass-through entity agreement between the Virginia Department of Health (the Department) (Assistance Listing 93.917) and the Inova Juniper Program (IJP), IJP is required to follow Health Resources and Services Administration (HRSA) guidelines related to the program. HRSA develops multiple policies to help grant recipients and subrecipients understand and carry out legislation applicable to Ryan White programs. Per the Policy Clarification Notice included on the official HRSA website for Ryan White, “Under the uniform administrative requirements, to the extent available, recipients and subrecipients must disburse funds available from program income, rebates, refunds, contract settlements, audit recoveries and interest earned on such funds before requesting additional cash payments.” As such, program income must be used for the purpose and subject to the conditions of the Federal award. The requirements within the pass-through entity agreement with the Virginia Department of Health are consistent with those required by the original Federal awarding agency, the Department of Health and Human Services (HHS), HRSA as included in the notice of award. Per the frequently asked questions (FAQs) presented by HRSA’s HIV/AIDS Bureau (HAB) for Policy Clarification Notice (PCN) 15-03, Clarification Regarding the Ryan White HIV/AIDS Program and Program Income, released on March 21, 2016, program income is gross income earned by the non-Federal entity that is directly generated by a supported activity or earned as a result of the Federal award during the period of performance (or grant period). Program Income includes the core medical and support services that HRSA considers allowable uses of Ryan White grant funds and the individuals eligible to receive those services. Condition IHS did not have appropriately designed internal controls in place to ensure that program income was applied to offset expenditures prior to requesting additional cash reimbursements each month during the grant period. Cause IJP has policies and procedures in place to ensure program income was applied to offset expenditures in its entirety prior to the end of the calendar and grant period. However, during the grant period, program income was not timely applied prior to cash reimbursement requests. Effect or potential effect Cash payments were being requested and reimbursed prior to application of program income. Questioned costs $109,290 of known questioned costs for Assistance Listing 93.917 $44,677 of known questioned costs for Assistance Listing 93.918 The costs questioned represent the amount of program income that should have been applied prior to requesting cash reimbursement. Identification of a repeat finding This is a repeat finding and relates to prior year finding 2023-002. Context Cash reimbursement requests under Assistance Listing 93.917 are submitted monthly. During our audit for Assistance Listing 93.917, we selected a sample of 4 months for testing and identified exceptions within 2 months where program income was not being applied timely to the cash reimbursement requests. The total amount of program income that should have been applied prior to requesting cash reimbursement was $32,843 for the 2 months selected. As a result, we obtained management’s summary of program income for the fiscal year and identified that a total of 7 months or a total of $109,290 did not apply program income prior to requesting cash reimbursements. Cash reimbursement requests under Assistance Listing 93.918 are submitted quarterly. During our audit for Assistance Listing 93.918, we selected a sample of 2 quarters for testing and identified that program income was not being applied timely to the first quarter cash reimbursement request. The cumulative program income not applied prior to the cash reimbursement for the first quarter was $44,677. As a result, we obtained management’s summary of program income for the fiscal year and identified that there were no other quarters impacted. Recommendation During the latter part of the fiscal year and as a result of prior year audit findings, IJP implemented various checkpoints in their processes to ensure that program income was applied prior to requesting cash reimbursements. IJP should continue to assess existing policies and procedures to ensure the program income balance is applied timely. HRSA recommends that recipients and subrecipients strive to proactively secure and estimate the extent to which program income will be accrued. View of responsible officials Management concurs with the finding and has implemented procedures to ensure the appropriate and timely application of program income.