Federal Award Finding and Questioned Costs
Finding Reference Number: 2022-002 – Activities Allowed or Unallowed, Allowable Costs/
Cost Principles, Eligibility and Program Income
Federal Program Information:
Federal Agency: U.S. Department of Health and Human Services
Pass-Through Entity: Virginia De...
Federal Award Finding and Questioned Costs
Finding Reference Number: 2022-002 – Activities Allowed or Unallowed, Allowable Costs/
Cost Principles, Eligibility and Program Income
Federal Program Information:
Federal Agency: U.S. Department of Health and Human Services
Pass-Through Entity: Virginia Department of Health
Pass-Through Entity Number: INORWB611-GY21; INORWB611-GY22
INORPS611-FY22; INORPS611-FY23
Awards: Assistance Listing Number 93.917 HIV Care Formula Grants
(Part B)
Award Periods: April 1, 2021 to March 31, 2022; April 1, 2022 to March 31, 2023
July 1, 2021 to June 30, 2022; July 1, 2022 to March 31, 2023
Description: Review and Retention of Eligibility Required Documentation
Type of Funding: Material Weakness in Internal Control Over Compliance
Recommendation: Inova Juniper Program’s (IJP) existing policies and procedures are in line with the
requirements of the pass-through agreement with the Department; however, IJP should continue to
evaluate whether appropriate oversight is performed to ensure that these policies and procedures are being
followed with regard to eligibility verification for all clients.
View of Responsible Officials: Management concurs with the finding and has implemented, during 2021
and 2022, procedures to ensure the appropriate oversight is performed regarding eligibility.
Name(s) of the Contact Person(s) Responsible for Corrective Action:
Christopher T. Smith, Vice President of Finance and Corporate Controller, 571-472-8122.
Christopher Trump, Senior Director of Financial Reporting, 571-373-2868.
Michael H. Lowen, Director, Grant Accounting, 571-472-8108.
Mara Carter, Senior Director Community Health, Inova Juniper Program, 703-321-2687
Corrective Action Planned: All exceptions noted during testing were from eligibility certifications prior
to the actions noted below. Patients were not due to have re-certifications done at the time the services
were provided. Below are the policies and procedures implemented and the control activities to ensure that
policies and procedures are being followed with regard to eligibility verification for all clients.
VDH Part B Eligibility standards were modified to help reduce the documentation burden in which
the annual eligibility screening was extended to a 24-month eligibility review and removal of the
six-month recertification requirement. This was incorporated within the VDH contract on April 1,
2022.
Effective November 1, 2021, the list of acceptable documents changed by VDH. Bank statements
were no longer an acceptable proof of residency and viral load values had to be included versus
only lab results with undetectable. Also, VDH implemented a new eligibility electronic health
record (EHR), Provide Enterprise, to help ensure all eligibility requirements are met for each Ryan
White patient. Although this was implemented statewide, Inova continued to utilize the Provide
Portal and went live with Provide Enterprise in January 2023. The existing Provide Portal at
Juniper did not have an income calculator or the ability to immediately provide feedback that the
required forms and eligibility requirement was not met. The new system in place, Provide
Enterprise, has both functionalities.
Inova has strict monitoring practices in place. The practice manager in 2021 and new Senior
Practice Manager who started in July 2022 reviewed 110-120 charts monthly, and our Business
Analyst performed a 10% reaudit of those charts. The audits completed in 2022 were a result of the
implemented processes due to the corrective action plan of the previous audit. These ongoing
audits assist management to closely monitor adherence to the changes adopted in 2021 and 2022.
If any gaps are noted during the audit, the Senior Practice Manager works with the team to fix
discrepancies within seven working days. The goal of the monitoring process is to ensure adopted
policies and procedures with respect to eligibility are followed.
In November 2022, a peer review process was implemented by the Senior Practice Manager to
ensure prior submission to any eligibility packet to VDH, there is a second independent review of
each packet. This ensures all internal processes are followed. After November 2022, weekly meetings continued with all eligibility team members and leadership. The peer review focuses
mainly on proof of documentation for each requirement and income calculations.
Inova Juniper Program implemented a revised policy in February 2023. Once Provide Enterprise
was fully implemented in February 2023, VDH also added a quality assurance meeting weekly to
review all previously submitted packets for the week. The goal is to identify any gaps and
opportunities in our processes. The revised policy focuses on the new EHR, Provide Enterprise,
capability and to ensure processes include use of the income calculator and compliance with
appropriate use of documents related to eligibility.
All team members went through a robust Provide Enterprise training and all new hires are required
to attend the same training. This training incorporates all the appropriate documents needed to be
eligible for Ryan White services as well as utilizing the income calculator. The Leadership team,
and our internal quality council, review our eligibility scorecards monthly and discuss any trends
or opportunities. In addition to the above, leadership also reviewed all job descriptions for our
current eligibility team. It was determined based on the scope of their role, that realignment was
necessary. The Patient Access Associate (PAA) I role did not require any healthcare or registration
experience in order to accurately perform their role. The job focused purely on customer service
experience and was an entry level position for the program. The PAA II role requires one year of
healthcare registration or revenue cycle experience and the PAA III roles require two years’
experience in healthcare registration or revenue cycle. Given the level of detail orientation required
for these positions and the ability to fully understand registration, HIPAA, insurance verification
and grant mandates, all individuals with the appropriate requirements that were identified as PAA I
roles were transitioned to PAA II and PAA III. Through attrition, all roles have successfully been
reassigned.
Planned Completion Date for Corrective Action Planned:
Corrective action plan has been implemented.