SECTION III ? FEDERAL AWARD FINDINGS AND QUESTIONED COSTS Material Weakness Finding 2022-001 Eligibility U.S. Department of Health and Human Services HIV CARE Formula Grants CFDA No. 93.917 Condition During the in-take and re-assessment process for the Ryan White HIV/AIDS Part B (RWB) program, case managers are responsible for (1) ensuring that all required forms and documents are received from clients, (2) reviewing those forms and documents for completeness and accuracy to verify that RWB program eligibility requirements are met; and (3) inputting the client?s information into e2 Hawaii, HHHRC?s system to monitor and track all RWB program clients. Effective April 1,2022, HHHRC updated their policies and procedures, requiring a manager or knowledgeable employee other than the case manager to sign off on the certification forms to document their review of eligibility determinations for completeness and accuracy. We selected a sample of 60 clients receiving assistance under the RWB program as part of our eligibility testing. Within the 60 files, we examined 61 annual or semi-annual certification forms dated prior to April 1, 2022, and 32 annual or semi-annual certification forms dated April 1, 2022 or later. Of the 61 certification forms dated prior to April 1, 2022, we noted 59 certification forms did not contain evidence of a review performed by a manager or a knowledgeable employee other than the case manager. Of the 32 certification forms dated April 1, 2022 or later, we noted 6 certification forms were not signed off by a manager or knowledgeable employee other than the case manager. Criteria The Uniform Guidance, as prescribed in 2 CFR section 200.305, requires that non-federal entities receiving federal awards establish and maintain internal control over federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Internal controls over compliance with RWB eligibility requirements should include formal policies and procedures to ensure that data used to determine eligibility are complete and accurate in compliance with RWB program requirements. Eligibility determination procedures should be performed by case managers and reviewed by a manager or knowledgeable employee. Cause HHHRC implemented a formal policy requiring a manager or knowledgeable employee other than the case manager to sign off on the annual and semi-annual certification forms for each client. This formal policy was implemented on April 1, 2022. As such, the certification forms that were prepared prior to this date were not reviewed in accordance with this policy. Effect Without appropriate internal controls, noncompliance with RWB eligibility requirements may occur. Refer to Finding 2022-002 for instances of noncompliance identified in the current year. Identification of a Repeat Finding This finding was reported as a federal award finding in the immediate previous audit as Finding 2021-001. Recommendation We again recommend that HHHRC adhere to established policies and procedures to ensure that eligibility determinations performed by case managers during the in-take and re-assessment process are reviewed by a manager or knowledgeable employee other than the case manager for completeness and accuracy.
Significant Deficiency Finding 2022-002 Eligibility U.S. Department of Health and Human Services HIV CARE Formula Grants CFDA No. 93.917 Condition During our audit, we selected a sample of 60 clients receiving assistance under the RWB program to ascertain whether those clients met the RWB program eligibility requirements. We noted that documentation supporting compliance with eligibility requirements for certain clients were incorrect, incomplete, or not provided. Specifically, we found that: - For 16 of the 60 clients selected, the file contained insufficient documentation to verify that the payer of last resort requirement was met. - For three of the 60 client files selected, the file did not have annual or semi-annual certification forms dated prior to certain dates of services, indicating that eligibility determinations were not performed prior to billing the Ryan White program. - For one of the 60 client files selected, the file contained certification forms that were more than 6 months apart. During that gap in certifications, services for the client were billed. - For one of the 60 clients selected, a bank statement was used for income determination. A bank statement alone does not document gross income as required to determine eligibility. Criteria Clients receiving assistance under the RWB program are subject to eligibility requirements contained in the Health Resources and Services Administration?s HIV/AIDS Bureau Policy Clarification Notice No. 13-02 Clarifications on Ryan White Program Client Eligibility Determinations and Recertification Requirements. To be eligible, clients must have a medical diagnosis of HIV/AIDS and be (a) a low-income individual, (b) a resident of the state, and (c) uninsured or underinsured, as defined by the state. Eligibility determination is required before participation in the RWB program during the in-take process. Re-assessments are performed at least once every 6 months thereafter. Per HHHRC?s Ryan White Eligibility Policy, these eligibility criteria are to be documented in their Annual Certification forms, and their Six-Month Semi-Annual Certification forms. HIV status must be documented by a written statement from a medical provider. Lab results may only be used on an interim basis. Residency must be documented with a State ID card or a driver?s license, lease agreement, utility bill, official government mail, bank statement, pay stub, or a verification letter from an agency providing the client with housing. Income levels must be documented with the most recent pay stubs covering 30 consecutive days, benefit statements, IRS tax transcripts, or a signed statement from the client attesting to no income or very low income. For the payer of last resort criteria, HHHRC?s policy states that they must, at a minimum, assess and re-assess the client?s eligibility for benefits such as MedQuest. In addition, HHHRC must make reasonable efforts to secure funding, besides the Ryan White program, including pursuing enrollment into health care coverage. Cause HHHRC did not adhere to established policies and procedures requiring that appropriate documentation be received and maintained to evidence compliance with eligibility requirements during the in-take and re-assessment process for the RWB program. As described in Finding 2022-001, HHHRC updated their formal policies and procedures effective April 1, 2022 to ensure that eligibility determinations performed by case managers during the in-take and re-assessment process are reviewed by a manager or knowledgeable employee other than the case manager. Effect HHHRC did not comply with the RWB program eligibility requirements for the instances noted above. Questioned Costs No questioned or known costs were identified. Identification of a Repeat Finding This finding was reported as a federal award finding in the immediate previous audit as Finding 2021-002. Recommendation We again recommend that HHHRC adhere to established policies and procedures requiring that appropriate documentation be received and maintained to evidence compliance with eligibility requirements during the in-take and re-assessment process for the RWB program. HHHRC should also consider expanding on their policies for payer of last resort, with more specific criteria for documentation required to support compliance with this requirement.
SECTION III ? FEDERAL AWARD FINDINGS AND QUESTIONED COSTS Material Weakness Finding 2022-001 Eligibility U.S. Department of Health and Human Services HIV CARE Formula Grants CFDA No. 93.917 Condition During the in-take and re-assessment process for the Ryan White HIV/AIDS Part B (RWB) program, case managers are responsible for (1) ensuring that all required forms and documents are received from clients, (2) reviewing those forms and documents for completeness and accuracy to verify that RWB program eligibility requirements are met; and (3) inputting the client?s information into e2 Hawaii, HHHRC?s system to monitor and track all RWB program clients. Effective April 1,2022, HHHRC updated their policies and procedures, requiring a manager or knowledgeable employee other than the case manager to sign off on the certification forms to document their review of eligibility determinations for completeness and accuracy. We selected a sample of 60 clients receiving assistance under the RWB program as part of our eligibility testing. Within the 60 files, we examined 61 annual or semi-annual certification forms dated prior to April 1, 2022, and 32 annual or semi-annual certification forms dated April 1, 2022 or later. Of the 61 certification forms dated prior to April 1, 2022, we noted 59 certification forms did not contain evidence of a review performed by a manager or a knowledgeable employee other than the case manager. Of the 32 certification forms dated April 1, 2022 or later, we noted 6 certification forms were not signed off by a manager or knowledgeable employee other than the case manager. Criteria The Uniform Guidance, as prescribed in 2 CFR section 200.305, requires that non-federal entities receiving federal awards establish and maintain internal control over federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Internal controls over compliance with RWB eligibility requirements should include formal policies and procedures to ensure that data used to determine eligibility are complete and accurate in compliance with RWB program requirements. Eligibility determination procedures should be performed by case managers and reviewed by a manager or knowledgeable employee. Cause HHHRC implemented a formal policy requiring a manager or knowledgeable employee other than the case manager to sign off on the annual and semi-annual certification forms for each client. This formal policy was implemented on April 1, 2022. As such, the certification forms that were prepared prior to this date were not reviewed in accordance with this policy. Effect Without appropriate internal controls, noncompliance with RWB eligibility requirements may occur. Refer to Finding 2022-002 for instances of noncompliance identified in the current year. Identification of a Repeat Finding This finding was reported as a federal award finding in the immediate previous audit as Finding 2021-001. Recommendation We again recommend that HHHRC adhere to established policies and procedures to ensure that eligibility determinations performed by case managers during the in-take and re-assessment process are reviewed by a manager or knowledgeable employee other than the case manager for completeness and accuracy.
Significant Deficiency Finding 2022-002 Eligibility U.S. Department of Health and Human Services HIV CARE Formula Grants CFDA No. 93.917 Condition During our audit, we selected a sample of 60 clients receiving assistance under the RWB program to ascertain whether those clients met the RWB program eligibility requirements. We noted that documentation supporting compliance with eligibility requirements for certain clients were incorrect, incomplete, or not provided. Specifically, we found that: - For 16 of the 60 clients selected, the file contained insufficient documentation to verify that the payer of last resort requirement was met. - For three of the 60 client files selected, the file did not have annual or semi-annual certification forms dated prior to certain dates of services, indicating that eligibility determinations were not performed prior to billing the Ryan White program. - For one of the 60 client files selected, the file contained certification forms that were more than 6 months apart. During that gap in certifications, services for the client were billed. - For one of the 60 clients selected, a bank statement was used for income determination. A bank statement alone does not document gross income as required to determine eligibility. Criteria Clients receiving assistance under the RWB program are subject to eligibility requirements contained in the Health Resources and Services Administration?s HIV/AIDS Bureau Policy Clarification Notice No. 13-02 Clarifications on Ryan White Program Client Eligibility Determinations and Recertification Requirements. To be eligible, clients must have a medical diagnosis of HIV/AIDS and be (a) a low-income individual, (b) a resident of the state, and (c) uninsured or underinsured, as defined by the state. Eligibility determination is required before participation in the RWB program during the in-take process. Re-assessments are performed at least once every 6 months thereafter. Per HHHRC?s Ryan White Eligibility Policy, these eligibility criteria are to be documented in their Annual Certification forms, and their Six-Month Semi-Annual Certification forms. HIV status must be documented by a written statement from a medical provider. Lab results may only be used on an interim basis. Residency must be documented with a State ID card or a driver?s license, lease agreement, utility bill, official government mail, bank statement, pay stub, or a verification letter from an agency providing the client with housing. Income levels must be documented with the most recent pay stubs covering 30 consecutive days, benefit statements, IRS tax transcripts, or a signed statement from the client attesting to no income or very low income. For the payer of last resort criteria, HHHRC?s policy states that they must, at a minimum, assess and re-assess the client?s eligibility for benefits such as MedQuest. In addition, HHHRC must make reasonable efforts to secure funding, besides the Ryan White program, including pursuing enrollment into health care coverage. Cause HHHRC did not adhere to established policies and procedures requiring that appropriate documentation be received and maintained to evidence compliance with eligibility requirements during the in-take and re-assessment process for the RWB program. As described in Finding 2022-001, HHHRC updated their formal policies and procedures effective April 1, 2022 to ensure that eligibility determinations performed by case managers during the in-take and re-assessment process are reviewed by a manager or knowledgeable employee other than the case manager. Effect HHHRC did not comply with the RWB program eligibility requirements for the instances noted above. Questioned Costs No questioned or known costs were identified. Identification of a Repeat Finding This finding was reported as a federal award finding in the immediate previous audit as Finding 2021-002. Recommendation We again recommend that HHHRC adhere to established policies and procedures requiring that appropriate documentation be received and maintained to evidence compliance with eligibility requirements during the in-take and re-assessment process for the RWB program. HHHRC should also consider expanding on their policies for payer of last resort, with more specific criteria for documentation required to support compliance with this requirement.
SECTION III ? FEDERAL AWARD FINDINGS AND QUESTIONED COSTS Material Weakness Finding 2022-001 Eligibility U.S. Department of Health and Human Services HIV CARE Formula Grants CFDA No. 93.917 Condition During the in-take and re-assessment process for the Ryan White HIV/AIDS Part B (RWB) program, case managers are responsible for (1) ensuring that all required forms and documents are received from clients, (2) reviewing those forms and documents for completeness and accuracy to verify that RWB program eligibility requirements are met; and (3) inputting the client?s information into e2 Hawaii, HHHRC?s system to monitor and track all RWB program clients. Effective April 1,2022, HHHRC updated their policies and procedures, requiring a manager or knowledgeable employee other than the case manager to sign off on the certification forms to document their review of eligibility determinations for completeness and accuracy. We selected a sample of 60 clients receiving assistance under the RWB program as part of our eligibility testing. Within the 60 files, we examined 61 annual or semi-annual certification forms dated prior to April 1, 2022, and 32 annual or semi-annual certification forms dated April 1, 2022 or later. Of the 61 certification forms dated prior to April 1, 2022, we noted 59 certification forms did not contain evidence of a review performed by a manager or a knowledgeable employee other than the case manager. Of the 32 certification forms dated April 1, 2022 or later, we noted 6 certification forms were not signed off by a manager or knowledgeable employee other than the case manager. Criteria The Uniform Guidance, as prescribed in 2 CFR section 200.305, requires that non-federal entities receiving federal awards establish and maintain internal control over federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Internal controls over compliance with RWB eligibility requirements should include formal policies and procedures to ensure that data used to determine eligibility are complete and accurate in compliance with RWB program requirements. Eligibility determination procedures should be performed by case managers and reviewed by a manager or knowledgeable employee. Cause HHHRC implemented a formal policy requiring a manager or knowledgeable employee other than the case manager to sign off on the annual and semi-annual certification forms for each client. This formal policy was implemented on April 1, 2022. As such, the certification forms that were prepared prior to this date were not reviewed in accordance with this policy. Effect Without appropriate internal controls, noncompliance with RWB eligibility requirements may occur. Refer to Finding 2022-002 for instances of noncompliance identified in the current year. Identification of a Repeat Finding This finding was reported as a federal award finding in the immediate previous audit as Finding 2021-001. Recommendation We again recommend that HHHRC adhere to established policies and procedures to ensure that eligibility determinations performed by case managers during the in-take and re-assessment process are reviewed by a manager or knowledgeable employee other than the case manager for completeness and accuracy.
Significant Deficiency Finding 2022-002 Eligibility U.S. Department of Health and Human Services HIV CARE Formula Grants CFDA No. 93.917 Condition During our audit, we selected a sample of 60 clients receiving assistance under the RWB program to ascertain whether those clients met the RWB program eligibility requirements. We noted that documentation supporting compliance with eligibility requirements for certain clients were incorrect, incomplete, or not provided. Specifically, we found that: - For 16 of the 60 clients selected, the file contained insufficient documentation to verify that the payer of last resort requirement was met. - For three of the 60 client files selected, the file did not have annual or semi-annual certification forms dated prior to certain dates of services, indicating that eligibility determinations were not performed prior to billing the Ryan White program. - For one of the 60 client files selected, the file contained certification forms that were more than 6 months apart. During that gap in certifications, services for the client were billed. - For one of the 60 clients selected, a bank statement was used for income determination. A bank statement alone does not document gross income as required to determine eligibility. Criteria Clients receiving assistance under the RWB program are subject to eligibility requirements contained in the Health Resources and Services Administration?s HIV/AIDS Bureau Policy Clarification Notice No. 13-02 Clarifications on Ryan White Program Client Eligibility Determinations and Recertification Requirements. To be eligible, clients must have a medical diagnosis of HIV/AIDS and be (a) a low-income individual, (b) a resident of the state, and (c) uninsured or underinsured, as defined by the state. Eligibility determination is required before participation in the RWB program during the in-take process. Re-assessments are performed at least once every 6 months thereafter. Per HHHRC?s Ryan White Eligibility Policy, these eligibility criteria are to be documented in their Annual Certification forms, and their Six-Month Semi-Annual Certification forms. HIV status must be documented by a written statement from a medical provider. Lab results may only be used on an interim basis. Residency must be documented with a State ID card or a driver?s license, lease agreement, utility bill, official government mail, bank statement, pay stub, or a verification letter from an agency providing the client with housing. Income levels must be documented with the most recent pay stubs covering 30 consecutive days, benefit statements, IRS tax transcripts, or a signed statement from the client attesting to no income or very low income. For the payer of last resort criteria, HHHRC?s policy states that they must, at a minimum, assess and re-assess the client?s eligibility for benefits such as MedQuest. In addition, HHHRC must make reasonable efforts to secure funding, besides the Ryan White program, including pursuing enrollment into health care coverage. Cause HHHRC did not adhere to established policies and procedures requiring that appropriate documentation be received and maintained to evidence compliance with eligibility requirements during the in-take and re-assessment process for the RWB program. As described in Finding 2022-001, HHHRC updated their formal policies and procedures effective April 1, 2022 to ensure that eligibility determinations performed by case managers during the in-take and re-assessment process are reviewed by a manager or knowledgeable employee other than the case manager. Effect HHHRC did not comply with the RWB program eligibility requirements for the instances noted above. Questioned Costs No questioned or known costs were identified. Identification of a Repeat Finding This finding was reported as a federal award finding in the immediate previous audit as Finding 2021-002. Recommendation We again recommend that HHHRC adhere to established policies and procedures requiring that appropriate documentation be received and maintained to evidence compliance with eligibility requirements during the in-take and re-assessment process for the RWB program. HHHRC should also consider expanding on their policies for payer of last resort, with more specific criteria for documentation required to support compliance with this requirement.
SECTION III ? FEDERAL AWARD FINDINGS AND QUESTIONED COSTS Material Weakness Finding 2022-001 Eligibility U.S. Department of Health and Human Services HIV CARE Formula Grants CFDA No. 93.917 Condition During the in-take and re-assessment process for the Ryan White HIV/AIDS Part B (RWB) program, case managers are responsible for (1) ensuring that all required forms and documents are received from clients, (2) reviewing those forms and documents for completeness and accuracy to verify that RWB program eligibility requirements are met; and (3) inputting the client?s information into e2 Hawaii, HHHRC?s system to monitor and track all RWB program clients. Effective April 1,2022, HHHRC updated their policies and procedures, requiring a manager or knowledgeable employee other than the case manager to sign off on the certification forms to document their review of eligibility determinations for completeness and accuracy. We selected a sample of 60 clients receiving assistance under the RWB program as part of our eligibility testing. Within the 60 files, we examined 61 annual or semi-annual certification forms dated prior to April 1, 2022, and 32 annual or semi-annual certification forms dated April 1, 2022 or later. Of the 61 certification forms dated prior to April 1, 2022, we noted 59 certification forms did not contain evidence of a review performed by a manager or a knowledgeable employee other than the case manager. Of the 32 certification forms dated April 1, 2022 or later, we noted 6 certification forms were not signed off by a manager or knowledgeable employee other than the case manager. Criteria The Uniform Guidance, as prescribed in 2 CFR section 200.305, requires that non-federal entities receiving federal awards establish and maintain internal control over federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Internal controls over compliance with RWB eligibility requirements should include formal policies and procedures to ensure that data used to determine eligibility are complete and accurate in compliance with RWB program requirements. Eligibility determination procedures should be performed by case managers and reviewed by a manager or knowledgeable employee. Cause HHHRC implemented a formal policy requiring a manager or knowledgeable employee other than the case manager to sign off on the annual and semi-annual certification forms for each client. This formal policy was implemented on April 1, 2022. As such, the certification forms that were prepared prior to this date were not reviewed in accordance with this policy. Effect Without appropriate internal controls, noncompliance with RWB eligibility requirements may occur. Refer to Finding 2022-002 for instances of noncompliance identified in the current year. Identification of a Repeat Finding This finding was reported as a federal award finding in the immediate previous audit as Finding 2021-001. Recommendation We again recommend that HHHRC adhere to established policies and procedures to ensure that eligibility determinations performed by case managers during the in-take and re-assessment process are reviewed by a manager or knowledgeable employee other than the case manager for completeness and accuracy.
Significant Deficiency Finding 2022-002 Eligibility U.S. Department of Health and Human Services HIV CARE Formula Grants CFDA No. 93.917 Condition During our audit, we selected a sample of 60 clients receiving assistance under the RWB program to ascertain whether those clients met the RWB program eligibility requirements. We noted that documentation supporting compliance with eligibility requirements for certain clients were incorrect, incomplete, or not provided. Specifically, we found that: - For 16 of the 60 clients selected, the file contained insufficient documentation to verify that the payer of last resort requirement was met. - For three of the 60 client files selected, the file did not have annual or semi-annual certification forms dated prior to certain dates of services, indicating that eligibility determinations were not performed prior to billing the Ryan White program. - For one of the 60 client files selected, the file contained certification forms that were more than 6 months apart. During that gap in certifications, services for the client were billed. - For one of the 60 clients selected, a bank statement was used for income determination. A bank statement alone does not document gross income as required to determine eligibility. Criteria Clients receiving assistance under the RWB program are subject to eligibility requirements contained in the Health Resources and Services Administration?s HIV/AIDS Bureau Policy Clarification Notice No. 13-02 Clarifications on Ryan White Program Client Eligibility Determinations and Recertification Requirements. To be eligible, clients must have a medical diagnosis of HIV/AIDS and be (a) a low-income individual, (b) a resident of the state, and (c) uninsured or underinsured, as defined by the state. Eligibility determination is required before participation in the RWB program during the in-take process. Re-assessments are performed at least once every 6 months thereafter. Per HHHRC?s Ryan White Eligibility Policy, these eligibility criteria are to be documented in their Annual Certification forms, and their Six-Month Semi-Annual Certification forms. HIV status must be documented by a written statement from a medical provider. Lab results may only be used on an interim basis. Residency must be documented with a State ID card or a driver?s license, lease agreement, utility bill, official government mail, bank statement, pay stub, or a verification letter from an agency providing the client with housing. Income levels must be documented with the most recent pay stubs covering 30 consecutive days, benefit statements, IRS tax transcripts, or a signed statement from the client attesting to no income or very low income. For the payer of last resort criteria, HHHRC?s policy states that they must, at a minimum, assess and re-assess the client?s eligibility for benefits such as MedQuest. In addition, HHHRC must make reasonable efforts to secure funding, besides the Ryan White program, including pursuing enrollment into health care coverage. Cause HHHRC did not adhere to established policies and procedures requiring that appropriate documentation be received and maintained to evidence compliance with eligibility requirements during the in-take and re-assessment process for the RWB program. As described in Finding 2022-001, HHHRC updated their formal policies and procedures effective April 1, 2022 to ensure that eligibility determinations performed by case managers during the in-take and re-assessment process are reviewed by a manager or knowledgeable employee other than the case manager. Effect HHHRC did not comply with the RWB program eligibility requirements for the instances noted above. Questioned Costs No questioned or known costs were identified. Identification of a Repeat Finding This finding was reported as a federal award finding in the immediate previous audit as Finding 2021-002. Recommendation We again recommend that HHHRC adhere to established policies and procedures requiring that appropriate documentation be received and maintained to evidence compliance with eligibility requirements during the in-take and re-assessment process for the RWB program. HHHRC should also consider expanding on their policies for payer of last resort, with more specific criteria for documentation required to support compliance with this requirement.