Finding No: 2024-001 Federal Agency: U.S. Department of Health and Human Services Assistance Listing Number: 93.917 Program: HIV Care Formula Grants Compliance Requirements: Activities allowed or unallowed/allowable costs, cash management and eligibility Award Year: October 1, 2023 through September...
Finding No: 2024-001 Federal Agency: U.S. Department of Health and Human Services Assistance Listing Number: 93.917 Program: HIV Care Formula Grants Compliance Requirements: Activities allowed or unallowed/allowable costs, cash management and eligibility Award Year: October 1, 2023 through September 30, 2024 (a) Criteria or Requirement 2 CFR 200.303 requires non-federal entities receiving federal awards to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Effective internal control should include procedures to ensure federal expenditures are accurately and completely reported on the SEFA. (b) Condition Found The System lacked sufficient internal controls to ensure the allowability of expenditures charged to the HIV Care Formula Grants. Our testing of a sample of 40 transactions totaling $6,054 identified three charges, totaling $488, that were incorrectly billed to the federal program. These costs, although related to services provided to patients, were determined unallowable for the following reasons: • The patients had other insurance coverage that was not billed prior to submission to the federal agency. • The patients did not meet all eligibility requirements and should have been excluded from reimbursement requests. Additionally, management did not maintain adequate documentation to support the annual reverification of patient eligibility, which is required prior to receiving services each year to remain eligible for the program. Due to these deficiencies, an expanded sample of 23 additional charges totaling $2,799 was tested. Of these,12 were determined to be unallowable, totaling $1,808. Charges related to certain costs related to July through September 2024 were related to an agreement that was not fully executed, resulting in an additional $97,782 of unallowable costs. Lastly, management did not retain sufficient supporting documentation for certain amendments to the grant agreement. This documentation is necessary to substantiate various elements of patient eligibility criteria under the grant. The grant amendment includes specific language that the grant is for the treatment of females over the age of 13, however both males and females were expensed and reimbursed under the grant. The male population for the remaining nine months of year represents $404,710. Our testing identified 26 out of our expanded sample of 63 total patients were males that were not also identified in the above testing results, totaling $3,835. (c) Cause The System’s review processes for charges recorded against the grant and submitted for federal reimbursement were ineffective in preventing unallowable charges and inaccurate amounts. Additionally, the System could not provide documentation for certain grant agreement amendments that would have supported the eligibility of specific patients. (d) Effect Federal funds were expended for unallowable purposes or for inaccurate amounts and evidence of the effective operation of management review controls was not maintained in accordance with Federal requirements. (e) Questioned Cost Expenditures related to patient charges of $222,016. (f) Statistical Sample The sample was not intended to be, and was not, a statistically valid sample. (g) Repeat Finding in the Prior Year Not a repeat finding (h) Recommendation We recommend that the System strengthen controls over the management review process to prevent unallowable costs and inaccurate amounts from being charged to Federal programs as well as ensure all relevant documentation is maintained in accordance with Federal requirements. (i) View of Responsible Officials Invoices were submitted to Mississippi State Department of Health (MSDH) for the HIV Care Formula Grants (CFDA No. 93.917); however, clinic staff did not conduct a thorough evaluation to verify continued eligibility for the program among patients who had previously qualified. Additionally, the lack of a fully executed agreement was a management oversight which contributed to the uncertainty regarding allowable billing to the program for reimbursement. Supporting documentation, including paperwork and emails, was also not properly maintained by management. (j) Corrective Action Plan We have reinforced our records retention policy to ensure proper documentation in support of eligibility determinations. Due to a variety of issues with this grant, including incomplete and conflicting guidance from the State of Mississippi, North Mississippi Health Services, Inc., has elected to terminate our participation in the program. As the program has concluded, no further actions are required due to expiration of the contract terms. The Fee-for-Service agreement ended June 30, 2024, while the Ryan White Part B Subgrant Agreement ended March 31, 2025. We will reimburse any funds received that were deemed unallowable due to expenditures occurring outside the grant period or patient ineligibility. Anticipated Completion Date: 10/31/2025 Name of Contact Person for Corrective Action: Sharon Nobles, Chief Financial Officer