Audit 398994

Condition: It was noted during the audit the Center was using outdated forms provided by the pass through agency to document program eligibility related to income and insurance documentation. Criteria: The pass-through agency, Michigan Department of Health and Human Services, provides a form for subrecipients to use for "Declaration of Residency/No Income or Support/Insurance Eligibility" (Form MDHHS-5422). When updated, previous versions are obsolete per MDHHS. Cause: The Center does not have a process in place to check for form updates published on the MDHHS website and relies upon emails or other notifications. Effect: Client eligibility could be improperly assessed in accordance with pass-through entity's requirements and state-wide plan. Perspective: This is a systemic finding. Repeat Finding: This is not a repeat finding. Recommendation: Encourage Program Director to periodically check for updates to forms and schedules being utilized for updates and ensure all staff are utilizing the correct versions.

Condition: We noted two instances where household income was updated but the supporting documentation (ex: 1099s, paycheck stubs, etc) were missing from the files. Additionally, we noted one instance where household income was not updated but there was a current checkstub. In all instances, the client was in compliance with the poverty guidelines. Criteria: To be eligibile for services under the HIV program, clients must have income below 500% of the federal poverty level. Both the Federal and State levels of oversight require pass-through entities to have documentation of eligibility determinations and controls in place to ensure only eligible clients are receiving services. Cause: The Center does not have a program specifc checklist or file review to ensure all documentation is included in the files. Effect: Household income could be incorrectly calculated and ineligible clients could be receiving services. Perspective: The total population was 140 and 20 cases were examined. Three cases did not include supporting documentation. Repeat Finding: This is not a repeat finding. Recommendation: Consider creating a checklist that case managers are required to complete to ensure files are complete and all information is maintained. Consider having household income changes reviewed before services can be continued.