Finding Text
2023-002 — Eligibility – Material Weakness in Internal Controls Over Compliance and
Noncompliance
Federal program information:
Funding agency: U.S. Department of Health and Human Services
Title: Urban Indian Health Service
ALN number: 93.193
Award years and number: 1/1/2018–12/31/2022, 75H70921C00004 &
H722IHS0138-20-00
Pass-through entity: (if applicable) N/A
Criteria: In accordance with the Center’s policy and federal guidelines, to be eligible for
healthcare services under the Urban Indian Health Service program, an adult individual must
provide documentation to the Center that would indicate that they are an enrolled member
of a federally recognized Tribe. An individual could prove their enrollment status by
submitting a copy of their tribal identification card or certificate of degree of Indian blood
(CDIB).
Condition: Five of the twenty-five individual files reviewed did not contain valid
documentation of Tribal identification that would indicate that these five individuals are
members of a federally recognized Tribe.
Questioned Costs: None.
Cause: The Center did not have a process in place that requires individuals to submit their
eligibility documentation during their initial visit. As a result, healthcare services were
provided to the five individuals without having their eligibility documents on file.
Effect: Without a process in place that requires obtaining and reviewing eligibility documents
for all applicants prior to providing healthcare services under the Urban Indian Health
Services Program, the risk of noncompliance with eligibility requirements increases.
Auditor’s Recommendations: We recommend developing and implementing internal control
policies and procedures to ensure that healthcare services under the Urban Indian Health
Services Program are not provided until all required eligibility documents have been
obtained, verified, and filed. In addition, we recommend training to staff and clear
communication to applicants regarding documentation requirements.
Management Response: All Nations Health Center recognizes this material weakness as part
of the insufficient training of all front desk staff. All Nations has reviewed the policies and
procedures for front staff duties and responsibilities and has re-trained its staff to ensure we
collect all pertinent documentation for all patients classified as “beneficiaries.” If the proper
documentation is not obtained, the patient status will remain as “nonbeneficiary".