Audit 6274

Criteria: Under this selected program, eligible individuals are those with low-income and those with HIV or, in certain circumstances, families of people with HIV. To the maximum extent practicable, services are to be provided to eligible individuals regardless of their ability to pay for the services and their current or past health condition (42 USC 300ff-15(a)(7)(A)). The Organization should maintain records providing evidence that the patients included under this program are eligible. Condition: During the compliance testing of 40 sample items, there were 9 instances where the Organization did not obtain and retain the patient’s proof of income to support eligibility under the program, and other cases where the information was obtained, but there was no evidence that anyone had reviewed the supporting documentation. However, there were no instances of lack of support for the requirement of evidence of a HIV diagnosis. Effect: Currently, there is no known monetary impact, improper expenditure of funds or questioned costs identified. However, if the Organization does not strengthen the internal controls in regard to the eligibility determination process, there is a possible effect on the ability of the Organization to obtain additional funding under this program if ineligible patients are being treated with grant funding. Cause: There is a lack of review in regard to obtaining, retaining and approving documentation that support individual's eligibility for the program. Recommendation: We recommend that the Organization review policies, procedures and practices in place over the controls related to obtaining, retaining and reviewing proof of income support for patients. Repeat Finding?: No Views of responsible officials and planned corrective actions: See attached letter. Reportable questioned costs: None

Criteria: Under this selected program, eligible individuals are those with low-income and those with HIV or, in certain circumstances, families of people with HIV. To the maximum extent practicable, services are to be provided to eligible individuals regardless of their ability to pay for the services and their current or past health condition (42 USC 300ff-15(a)(7)(A)). The Organization should maintain records providing evidence that the patients included under this program are eligible. Condition: During the compliance testing of 40 sample items, there were 9 instances where the Organization did not obtain and retain the patient’s proof of income to support eligibility under the program, and other cases where the information was obtained, but there was no evidence that anyone had reviewed the supporting documentation. However, there were no instances of lack of support for the requirement of evidence of a HIV diagnosis. Effect: Currently, there is no known monetary impact, improper expenditure of funds or questioned costs identified. However, if the Organization does not strengthen the internal controls in regard to the eligibility determination process, there is a possible effect on the ability of the Organization to obtain additional funding under this program if ineligible patients are being treated with grant funding. Cause: There is a lack of review in regard to obtaining, retaining and approving documentation that support individual's eligibility for the program. Recommendation: We recommend that the Organization review policies, procedures and practices in place over the controls related to obtaining, retaining and reviewing proof of income support for patients. Repeat Finding?: No Views of responsible officials and planned corrective actions: See attached letter. Reportable questioned costs: None